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privacy policy

This Privacy Policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PII in accordance with our website.

What personal information do we collect from the people that visit our blog, website or app?
We do not collect PII from visitors of our site. Cookies are utilized to collect general information about user behavior in order to improve the website and user experience (see “Do we use cookies?” and “We use cookies to:” below).

When do we collect information?
We collect information from you when you enter information on our site, for example a contact form or Request for Quote (RFQ).

How do we use your information?
We may use the information we collect from you when you register, submit a contact form, sign up for our newsletter, respond to a survey or marketing communication, or use certain other site features in the following ways:

  • To quickly process your transactions and requests,
  • To ask for ratings and reviews of services or products, and
  • For future correspondence

How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information.

Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, they are used to determine how users arrive to the site, which pages are visited, and if similar pages are visited on return visits. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to: Understand and save user’s preferences for future visits. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu or Settings to learn the correct way to modify your cookies. If you turn cookies off, some of the features that make your site experience more efficient may not function properly. It will not affect the user’s experience on this site if you disable cookies.

Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your PII.

Third-party links
We do not include or offer third-party products or services on our website.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.  https://support.google.com/adwordspolicy/answer/1316548?hl=en

No third party advertisements are used on this website. However, at times, links to third party sites are used. These links are not necessarily endorsements or supported by CQ fluency, but are provided as resources, citations, and additional information. The website visitor assumes all risk of visiting any cites that are linked to from our website.

California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting PII from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared.

For more information visit http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:
Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes on our Privacy Policy Page.
You can change your personal information:

  • By emailing us
  • By calling us

How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking.

Children Online Privacy Protection Act
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify you via email within seven (7) business days. We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions.
  • Process orders and send information and updates pertaining to orders.
  • Send you additional information related to your product and/or service.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to the following:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using a link included in each email.

If at any time you would like to unsubscribe from receiving future emails, you should follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

EU-U.S. Data Privacy Framework Policy
Introduction and Overview

As a global provider of language translation and technology services, CQ fluency is trusted by its customers and employees to safeguard the confidentiality and integrity of their content in any language and locale. CQ fluency has deployed a variety of measures to ensure that this content is protected appropriately and is transferred in accordance with applicable law. When that content consists of ‘personally identifiable information’ or ‘Personal Data’, CQ fluency has implemented special procedures for processing, storage and transfer of Personal Data that are designed to meet the requirements of the EU-U.S. Data Privacy Framework, the Swiss-U.S. DPF and the UK Extension to the EU-U.S DPF. These procedures are detailed in this Privacy Policy and apply to all Personal Data that CQ fluency processes, transfers or stores, whether from employees, vendors or customers. CQ fluency complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the Swiss-U.S. DPF and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. CQ fluency has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit  https://www.dataprivacyframework.gov.

Generally, in the course of its business, CQ fluency will have access to Personal Data consisting of personnel information related to its Personnel and business contact information of its Business Contacts and Contractors (Business Contact Information) or any such information that is contained in materials provided to CQ fluency for the purpose of obtaining translation, testing or other commercial services.

In addition to adopting the EU-U.S. DPF, CQ fluency has also elected to adopt the EU Standard Contractual Clauses (Processors) with respect to the transfer of Personal Data from the European Union (and the United Kingdom) to the United States of America.

CQ fluency’s practices with respect to the EU-U.S. DPF are self-certified and reflect the current guidelines as outlined in the EU-U.S. DPF. In the event of any changes to the EU-U.S. DPF, CQ fluency undertakes to update and circulate this policy.

Independent Resources for Privacy Complaints

In compliance with the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to the EU-U.S DPF,  CQ fluency commits to cooperate and comply respectively with the advice of the panel established by the EU Data Protection Authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

For EU, Swiss or UK individuals with inquiries or complaints regarding our Privacy Policy: Contact Mariana Taylor, DPO for the EU at data-privacy@cqfluency.com

For U.S. individuals with inquiries or complaints regarding our Privacy Policy: Contact Leigh Turgut, DPO for the U.S. at data-privacy@cqfluency.com

CQ fluency has a policy of responding to individuals within thirty (30) days of an inquiry or complaint. In compliance with the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to the EU-U.S. DPF, CQ fluency commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to the EU-U.S. DPF to the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of AAA-ICDR are provided at no cost to you. Individuals can invoke binding arbitration under certain conditions for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, please see Annex I of the PDF for additional information.

If the dispute involves human resources personal information or information collected in the context of an employment relationship, we will cooperate with the competent EU, Swiss or UK data protection authorities and comply with the advice of such authorities.

CQ fluency has further committed to cooperate with the panel established by the EU Data Protection Authorities (DPAs) with regard to unresolved EU-U.S. DPF complaints concerning data transferred from the EU, including human resources in the context of the employment relationship.

Scope
This Policy applies to all Personal Data received by CQ fluency in any format, irrespective of country of origin or transfer, or citizenship of the Data Subject.

Notice
CQ fluency treats all Personal Data received from any individual, including but not limited to Personnel, Business Contacts and Contractors, as confidential. CQ fluency notifies all identified Data Subjects regarding the types of Personal Data collected and its intended uses. CQ fluency does not use Personal Data for purposes that are incompatible with the EU-U.S. DPF.

Global Network
CQ fluency works with a global network of freelance suppliers in performance of translation, testing, consulting and localization services. These suppliers may be exposed to Personal Data in performance of these services. However, they are at all times subject to confidentiality agreements and are authorized only to use such information within the scope of performance of the services. All suppliers handling Personal Data must also agree to the EU Standard Contractual Clauses.
When CQ fluency handles Personal Data received directly from Personnel in the European Economic Area (EEA), it will inform the Personnel regarding the type of Personal Data being collected, the purpose for collecting the information, the types of Personnel and Third Parties likely to be exposed to this information in performance of services, and that individual’s choices in limiting such exposure.

Any Contractor has the right to terminate its working relationship with CQ fluency and request the deletion of Personal Data pertaining to them. However, CQ fluency will continue to maintain its historical business records in such a way so that CQ fluency 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 CQ fluency does not accidentally contact them for projects in the future.

CQ fluency may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Choice
CQ fluency’s Personnel and Business Contacts have the opportunity to opt out of (i) allowing CQ fluency to disclose his or her Personal Data to a Third Party and (ii) allowing CQ fluency to Process Personal Data for a purpose other than its original purpose.

Personnel can ask questions and effectuate his or her opt-out as applicable, by sending an email to the local HR Representative, or other applicable contact person designated by CQ fluency, or by accessing the appropriate system, as applicable. Business Contacts can ask questions and effectuate his or her opt-out as applicable by sending an email to the applicable business contact at CQ fluency, other applicable contact person designated by CQ fluency, or by accessing the appropriate system. However, CQ fluency will continue to maintain its historical business records in such a way so that CQ fluency may retain its historical knowledge and relationships concerning any legal or regulatory inquiries which may later arise and retain information for legitimate business purposes.

With regard to Personal Data that CQ fluency receives in connection with the employment or business relationship, CQ fluency will use such Personal Data only for the purpose for which it was originally collected. If CQ fluency intends to disclose Personnel Personal Data to a Third Party for any purpose other than its original purpose, CQ fluency will provide the Personnel or Business Contact with an opportunity to opt-out of such uses.

Accountability for Onward Transfers

CQ fluency typically does not disclose data to third parties unless required to for regulatory or legal reasons. CQ fluency will obtain assurances from Third Parties and Vendors that they will safeguard Personal Data consistent with this Policy. CQ fluency will take all precautions with respect to this Policy to prevent, contain, or stop disclosure contrary to such entity’s confidentiality obligations.

To transfer personal information to a third party acting as a controller, CQ fluency will comply with the Notice and Choice Principles. CQ fluency will enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify the organization if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.
CQ fluency may be liable for the appropriate onward transfer of an EU individual’s data to third parties.

To transfer personal data to a third party acting as an agent, CQ fluency will:

  • Transfer such data only for limited and specified purposes;
  • Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles;
  • Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles;
  • Require the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles;
  • Upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing;
  • Provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.

Access And Correction

CQ fluency will provide individuals with reasonable access to the Personal Data they have provided to CQ fluency and will allow them to review and correct this Personal Data as required by the EU-U.S. DPF, the Swiss U.S. DPF and the UK extension to the EU-U.S. DPF. Access to review this Personal Data will be granted except where the burden or expense of providing access would be disproportionate to the risks to the Personnel’s privacy or where the rights of others would be violated.

CQ fluency conducts a periodic assessment in order to verify that this Policy is published, accurate, comprehensive, prominently displayed, implemented, accessible and conforms to the principles of the EU Data Directive. CQ fluency maintains procedures for training Personnel in the implementation of the Policy and has in place internal procedures for periodically conducting objective reviews of compliance.

  • Individuals can access their data by calling +1 (201) 487-8007 and requesting to speak with the Director of Compliance regarding access to personal data or emailing data-privacy@cqfluency.com
  • Data can be reviewed by the individual, verified (if needed) and ensure the processing of data is in line with this Privacy Policy.
  • Individuals can request to amend or delete their data when it is inaccurate or handled in violation of this Privacy Policy.

Data Integrity
CQ fluency ensures that all applicable Personal Data is accurate, complete, current and reliable for its intended use. All Personnel should help CQ fluency meet this objective by updating their information immediately in the event that Personal Data changes, either by notifying the local HR Representative, or other applicable contact person designated by CQ fluency, or updating the information themselves, if applicable. To the extent feasible, CQ fluency restricts access to Personal Data to those Personnel or Agents of CQ fluency that have a legitimate business need for such access.

Data Security
CQ fluency undertakes to protect Personal Data from loss, misuse, and from unauthorized access, disclosure, alteration, and destruction. These precautions include password protections for online information systems and restricted access to Personal Data. CQ fluency may assign different types of data different security levels, with appropriate corresponding security precautions. CQ fluency also restricts access to Personal Data to those Personnel or Agents of CQ fluency that have a legitimate business need for such access.

Enforcement

CQ fluency ensures to internally verify adherence to this Policy once per year as part of its annual review and internal compliance measures. CQ fluency will use its best commercial efforts to ensure that compliance with this policy is followed and that the Policy remains accurate, comprehensive, and in conformance with the EU-U.S. DPF, the Swiss-US DPF and the UK extension to the EU-U.S. DPF.

In the event that any issues pertaining to this Policy cannot be resolved internally, CQ fluency agrees to adhere to the dispute resolution processes as outlined in the EU-U.S. DPF, the Swiss-US DPF and the UK extension to the EU-U.S. DPF.

CQ fluency is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

General Definitions

  • “Agent” means a Third Party that Processes Personal Data solely on behalf of and under the instructions of CQ fluency.
  • “Business Contact” means a current, past, or prospective customer of CQ fluency or any of its subsidiaries and other individuals with whom it is, has been or may be engaged in commercial relationships.
  • “Vendor” means an individual who, as a non-employee and under contract with CQ fluency, provides translation and/or other services to CQ fluency.
  • “Data Subject” is an identified or identifiable natural person.
  • “Personal Data” is any information that is recorded in any form relating to an identified or identifiable natural person.
  • “Personnel” refers to any employee, former employee, job applicant, director or Vendor of CQ fluency or its subsidiary companies.
  • “Process (-ing, -es, -ed)” means to perform any operation upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
  • “Third Party” is any natural or legal person, public authority, agency or any other body other than the Data Subject, CQ fluency, Agent or Vendor.

Other covered entities:

  • AscendantUSA
  • adaQuest, Inc.

Modifications
CQ fluency may update this Privacy Policy at any time by publishing an updated version on our website and in CQ-IS-SOP-15, however we will not update this Policy in contravention of the DPF Principles.

Contact Us
If there are any questions regarding this Privacy Policy, you may contact us using the information below.
CQ fluency, LLC
2 University Plaza Drive, Suite 406
Hackensack, NJ 07601
United States
+1.201.487.8007
compliance@cqfluency.com

effective May 2022

last updated May 2024