Privacy Policy

INTRODUCTION

About Us

Happy Scribe Limited ("Happy Scribe") is a private company limited by shares incorporated in Ireland with company number 604917 and having a registered office at The Black Church, Saint Mary's Place North, Dublin 7 ("we"/"us"/"our"). We provide transcription, subtitling and translation services to our customers (the "Services") through our online platform at https://www.happyscribe.com (the "Website").

About this Privacy Policy

Data protection refers to the safeguarding of personal data, as defined by the General Data Protection Regulation ("GDPR"), which encompasses any information pertaining to an identified or identifiable natural person. An identifiable natural person is someone who can be directly or indirectly identified, particularly through an identifier such as a name, identification number, or other specific attributes. This Privacy Policy (the "Policy") outlines crucial information about your rights concerning the processing of your personal data for the purpose of using the website. It also specifies the basis on which any personal data we collect from you.

In compliance with data protection regulations, your personal data will:

We take our responsibilities seriously with regard to the processing of personal data. Please note that our Website may contain links to third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

The Website is not aimed at children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, please do not use our Services or provide any information to us through the Website.

This Policy should be read alongside, and in addition to, our Website Terms of Use, which can be found at: https://www.happyscribe.com/terms.

I. USERS PERSONAL DATA

a) Identity and contact information of the Data Controller

Unless we specify otherwise (see section II below) or unless we have entered into a different agreement with you, we will be what's known under the GDPR as the "controller" of the personal data you provide to us.

b) Personal information we may process about you

We collect and process the following data about you for the following purposes:

Personal data you give to us in order to use our services: We collect data about you that you provide to us by registering or filling in forms on our website, or by corresponding with us by phone, email, or other means. This includes the data collected:

In particular, we process the following information:

We collect this information to improve the content and navigation of our Website. To collect this information, we use cookies, which are stored on your browser in accordance with your cookie settings. For more information about cookies and how we use them, please refer to our Cookies Policy at: https://www.happyscribe.com/cookies_policy

Personal Data Why are personal data processed? Period for which data will be stored Legal basis for processing
Identity Data 1) To register you as a new customer. 2) To provide you with secure access to the platform. 3) Surveys and review We will store your identity data until you delete your account. We may share your identity data with third parties to help store your account information. 1) Performance of a contract with you. 2) Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business).
Identity Data Financial Data We collect this information to prepare the customer invoices. We will store your personal data until you delete your account or until any outstanding debts for services provided have been resolved. We may share your identity/financial data with third parties to help manage your financial information. 1) Performance of a contract with you. 2) Necessary for our legitimate interests.
Identity Data Technical Data To manage our relationship with you, including notifying you about changes to the Services, or our Privacy Policy. We will store your personal data until you delete your account. We may share your identity data with third parties to help store your account information. 1) Performance of a contract. 2) Necessary to comply with a legal obligation. 3) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and Services).
Identity Data Technical Data To provide you with information about services we offer that are similar to those that you have enquired about. We will store your personal data until you delete your account. Necessary for our legitimate interests (to develop our products or Services and grow our business).
Identity Data Technical Data Where you have given us your consent to do so, to provide you with information about other services we feel may interest you. We will store your personal data until you withdraw the consent you have given us to send you information. Consent.
Identity Data Technical Data To ensure that content is presented in the most effective manner for you and for your computer or device. We will store your personal data until you delete your account. Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).
Identity Data Technical Data To administer and protect our business, our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We will store your personal data until you delete your account. Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure).
Technical Data To use data analytics to improve or optimize our Site, marketing, customer relationships and experiences. We will store your personal data until you delete your account. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).
Technical Data To train machine learning algorithms. We will store your personal data until you delete your account. Necessary for our legitimate interests (to develop our products or Services and grow our business).

Data that is received from third parties. We will receive personal data about you from third parties such as:

*Users that choose to upload files using the YouTube upload integration are agreeing to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms), which are related to the Google Privacy Policy (http://www.google.com/policies/privacy).

c) We will disclose your personal information to third party recipients

d) International Transfers

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area ("EEA"), where the privacy and data protection laws may not be as protective as those in your jurisdiction, in accordance with Articles 45 and 46 of the GDPR. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.

For more information about this and the safeguards in place relating to the transfer, please contact us by email at dataprotection@happyscribe.com

e) Keeping Data Secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

f) Your Rights

As a Data Subject, you have the following rights:

Right of Access You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to dataprotection@happyscribe.com. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested.

There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

Right of Restriction You may restrict us from processing your personal data in any of the following circumstances:

Right of Rectification and Right to be Forgotten If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at dataprotection@happyscribe.com.

Right to Data Portability Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.

Right to Object You have the right to object to the processing of your personal data at any time:

To exercise your right to object at any time, please email dataprotection@happyscribe.com.

Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.

The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned.

g) Marketing Communications

General.

We will process your personal data to send you marketing communications regarding products or similar services to those initially contracted.

Your right to object.

You have the right to object to the processing of your personal data for our marketing communications by contacting us at dataprotection@happyscribe.com. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us.

h) How Long We Keep Your Information:

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. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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. For more information about our data retention policies please contact us at dataprotection@happyscribe.com.

i) If You Fail To Provide Personal Data.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We store the data for the duration of the contract term and, if applicable, for the duration of statutory retention periods. We will delete your account upon your request after the cancellation of the account.

II. CONTENT DATA

In order for us to provide you with our Services, you will need to share with us texts, audios or video files (hereinafter, "Content" ) for us to provide transcription, subtitling and translation. Such Content may include personal data. If this is the case, we will process personal data included in the Content acting as what's known under the GDPR as the "Processor" and while doing so we will comply with the following obligations:

a) Data Processing

We will only process personal data included in the Content within the scope of the services we offer, excluding any use for our own purposes or for statistical purposes.

We will only grant access to personal data to those employees and/or third parties necessary for providing services to you. We guarantee that our employees and/or third parties are informed of the processing they can carry out with respect to the data provided by you and have the necessary training and expertise in data protection to provide the contracted services. We will ensure the confidentiality of the data and respect the security measures implemented. You reserve the right to monitor the actions of our employees through internal measures.

We, including our employees and/or third parties, commit to not disclose, transfer, assign, or communicate the files or personal data contained therein to any third party, verbally, in writing, electronically, on paper, or through computer access, not even for their preservation, without prior written authorization from you and always within the scope and purpose of this agreement.

b) Security Measures

We undertake to adopt the technical and organizational measures that may be necessary to ensure the security, confidentiality, and integrity of personal data. We will also prevent their alteration, loss, processing, or unauthorized access, taking into account at all times the state of technology, the nature of the data, and the risks to which they are exposed.

c) Notification of Incidents/Security Breaches

In the event of a security incident, such as destruction, loss, modification, accidental disclosure, unauthorized or illegal access to personal data ("Security Incident or Breach"), we, as Processor, shall notify you, as Controller, without undue delay of any breaches of the security of personal data, together with all relevant information for documentation and communication of the incident. Notification shall not be required when it is unlikely that such security breach constitutes a risk to the rights and freedoms of natural persons.

d) Subcontractor

In the event that we engage another Processor, we will inform you by updating this Policy. We will formalize a written service provision contract with each subcontracted company. The contract must ensure compliance with the obligations set forth in this Policy, as well as the same security and other conditions established. In this way, the subcontractor, who will also have the status of Processor, is equally obliged to comply with similar obligations as we, as Processor. For more information about subprocessors, please contact us by email at dataprotection@happyscribe.com

e) International data transfer

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area ("EEA"), where the privacy and data protection laws may not be as protective as those in your jurisdiction, in accordance with Articles 45 and 46 of the GDPR. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer. For more information about this and the safeguards in place relating to the transfer, please contact us by email at dataprotection@happyscribe.com

f) Retention, Return and Deletion of Personal Data

Upon termination or expiration of the relationship between the parties (whether due to closure of the user\'s account or at their express request), we will return or destroy all personal data of the Content that you have provided us for the provision of the Services. However, this obligation will not apply if, due to applicable regulations, we need to retain such data.

We will be able to store the Content for training our machine learning algorithms. This will allow us to continuously improve the quality of our service for you. All personal data in the Content that we stored will be anonymised.

g) Professional secrecy/confidentiality

We are bound by professional secrecy with respect to any personal data to which we have access due to our provision of Services to the Controller. This obligation will continue even after the relationship between the parties has ended, thus constituting an indefinite obligation.

You, as the data controller, represent and warrant that the personal data included in the content has been collected in accordance with applicable laws, and that the disclosure of such personal data to us for the purposes mentioned herein is compliant with applicable laws.

III. ADDITIONAL INFORMATION

Third Party Material

We always endeavour to deal with vendors and other third parties who are GDPR compliant or, in the case of the third parties located outside of the EEA, who have adequate security measures in place to safeguard the security of personal data. We comply with all the GDPR requirements when engaging with those third parties. That said, we, our employees and agents accept no liability however arising for the content or reliability of any third-party materials or websites referenced by hyperlink or other means on the Site or for the data collection and use practices or security measures used by such third parties. If you submit personal data to any of those sites, your personal data is governed by their privacy policy. We encourage you to carefully read their privacy policies.

Changes To This Privacy Policy

We reserve the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations. If required under the applicable laws, we will inform you of any material change of this Privacy Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@happyscribe.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Effective Date of this Policy: 15th January 2024

Contact us

If you have any questions or complaints relating to this Policy, please contact us at:

Happy Scribe, The Black Church, Saint Mary's Place North, Dublin 7

Email: dataprotection@happyscribe.com

Supervisory Authority

We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that wes have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Data Protection Commission in Ireland.