Privacy Policy

Scope – This Privacy Policy applies generally to personal data received by Glodom in any format” to “This Privacy Policy applies generally to personal data received by Glodom Language Solutions Co., Ltd. in any format. Glodom will ensure all global data handled by our 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.  Therefore, for more detailed information concerning our privacy practices with respect to your personal data, please select one of the following specific categories of data subjects and its associated Privacy Policy:

Who are we?
Glodom Language Solutions Co., Ltd. and its affiliates and subsidiaries (collectively, “Glodom”) may be a data controller of your personal data (also known as personal information), which means that Glodom 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, Glodom 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 such 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 its implementing regulations.

How do we process your personal data?
Glodom 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 Glodom may be stored in Glodom’s data center in the United States.  For details concerning the purposes and locations with respect to which we process your personal data, please utilize the applicable link above under “Scope.”

What personal data do we collect and how do we process your personal data?
Please utilize the applicable link above under “Scope” to find more detail concerning the categories of personal data that we collect from you. Glodom complies with its obligations under applicable privacy laws 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 Glodom may be stored in Glodom’s data center in the United States.  For details concerning the purposes and locations with respect to which we process your personal data, please utilize the applicable link above under “Scope.

Why are we collecting your personal data?
For details concerning the purposes with respect to which we process your personal data, please utilize the applicable link above under “Scope.”

What is the legal basis for processing your personal data?
For details concerning the legal bases with respect to which we process your personal data, please utilize the applicable link above under “Scope.”

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.

Sharing your personal data
For details concerning third parties with whom we may share your personal data, please utilize the applicable link above under “Scope.”

Sale of personal data
We do not sell your personal information.

 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 and 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, Glodom has elected to adhere to enforcing the EU Standard Contractual Clauses (Processors) and the Privacy Shields concerning the transfer of personal identifiable data from the European Union to the United States of America, including adhering to the requirements effective under the General Data Protection Regulation (GDPR). Glodom complies with the EU-U.S. Privacy Shield Framework and 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 the European Union, the United Kingdom and/or Switzerland to the United States, respectively. Glodom has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. 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 Privacy Shields. Any changes made necessary will be reflected in an update to this policy and disseminated. Glodom'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 Glodom 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. Also, cookies may also be used to track how you use the site to target ads to you on other websites. When any clients visit Glodom's website, Glodom does not track Personal Data, names or email addresses. Instead, Glodom 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. 

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 Privacy Shield frameworks. 

Notice – Glodom 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 Glodom.  

Glodom utilizes a network of over 3,000 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 will be 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 Glodom and request the deletion of Personal Data pertaining to them. However, as permitted by applicable law, Glodom will continue to maintain its historical business records in such a way so that Glodom may retain its historical knowledge and relationships concerning 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 Glodom does not accidentally contact them for projects in the future.

Choice – – Glodom's 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 Glodom Client Services Representative. Additionally, if there is a specific concern about the Personal Data found in the information provided to process a language services project (such as source, reference material, etc.), we recommend redacting this information prior to sending it to Glodom or discussing alternative solutions with your Glodom 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.

Data Integrity – Glodom is dedicated to ensuring that all data maintained is accurate, updated, and relevant for the use contemplated by the CVE 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 Glodom and remain proactive with requesting access to any Personal Data and advising Glodom of the need for corrections as needed.

Data Security – Glodom 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 Glodom 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. Glodom's information security is managed internally and is routinely audited to ensure conformity with Glodom procedures and recommended industry standards. Independent Recourses for Privacy Complaints and Contact Information In compliance with the Privacy Shield Principles, Glodom commits to resolve complaints about our collection or use of your personal information. To exercise all relevant rights, queries or complaints, please contact: Fuki Zhang Data Privacy Officer szlc@hkgsl.com

Enforcement 
Glodom undertakes to verify compliance with its Privacy Policy not less than once per year and in connection with Glodom's annual review and internal compliance measures. Glodom 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 Glodom's Privacy Officer directly 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. Glodom 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.

Effective: Feb 2020