Neon Creative Technology Limited is a limited liability company incorporated in England and Wales. Neon is the controller of and responsible for the Site and the Platform.
If you have any questions about this policy including exercising your legal rights, please contact us at firstname.lastname@example.org.
Collection and Use of personal data
The personal data gathered by us through the Site and Platform relates to our customers and the individuals featured in the videos our customers upload. We collect this personal data where it is necessary in order for us to provide the Site and the Platform to you or where it is necessary for the purposes of legitimate interests pursued by you or us. Some of this data will be collected by third parties on our behalf. We collect the following categories of personal data for the following reasons:
- Account Details: To use the Platform, you will be required to create an account by providing your name, details of your employer and your email address. This will be used for logging into the Platform and you will receive email notifications of events taking place inside CaptionHub which you can opt out of at any time. We will also collect data on user subscriptions, upgrades and cancellations and this will be recorded against your account profile to allow us to manage the service we provide to you. If you elect to pay via credit card your credit card details will be processed via a third party, we will not have access to this data.
- Video Information: When you upload material to the Platform, for example video, timed text, attachments and so on this is likely to contain personal data of those featured in the video, we will process this to the extent necessary to provide you with the captioning services and will share the data with various third party service providers who help us to provide the captioning services to you.
- Platform Activity Information: Through your use of the Platform, we collect and process information about how users interact with the Platform, including tracking and timestamping all activity within the Platform (for example logins, uploads, downloads, approvals, handovers and so on). This helps us understand how people are using the Platform, and allows us to bill for usage.
- Assistance Information: If you submit an enquiry, report a problem with the Platform (usually via online form submission) or respond to a communication from us, we may be provided with certain personal data such as your name and email address, and we will receive the information contained in the correspondence (which will contain your personal data that you provide to us).
- Platform Performance Information: We constantly monitor the Platform for performance, and we are proactively warned if a user encounters an error. We cross reference the error with the user, to allow us to recreate the issue, and to allow us to make any fixes as quickly as possible. We also capture our user’s interaction with the Platform through screen captures, this allows us to make better design choices for the Platform (for the avoidance of doubt, sensitive information such as passwords and credit card details aren’t collected through this process).
- Linguist Performance Information: We also track how much has changed in between translations, and how much time a user has spent being assigned to a particular set of captions. We monitor how many linguists are assigned to a particular project, time taken on a project and statistics relating to the video being translated, such as the word count and duration. We may display this information publicly or share it with third parties.
- Marketing Information: You may provide us with your name and email address and other personal data if you sign up to receive marketing communications from us or to request a Platform demonstration.
We may need to share your personal data with selected third parties in the following limited circumstances:
- Third party service providers: This may include providers of certain systems and services that we use to host, administer and maintain the Site and the Platform.
- Third party service providers for marketing purposes: If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms. We will only use your personal data for our own marketing purposes and won’t share your data to allow third parties to market to you.
- To comply with legal or regulatory requests: If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.
- Prospective buyers or sellers: In the event that Neon buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Neon (or substantially all of its assets) is acquired by a third party, your personal data held by Neon, or within such assets, may be transferred to such third party.
International and group company transfers
We will not transfer your personal data outside of the European Union, except to selected third parties that we have instructed to help us provide the Site and Platform to you, for example some of our marketing and CRM software providers are based in the United States.
Where such transfers are to a county outside the European Union, we rely on one of the European Commission’s adequacy decisions (for example, relying on a Privacy Shield certification where the transfer contains a US entity) or we will use reasonable efforts to put in place appropriate safeguards to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission. Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies.
If there are any other circumstances (for example where we are not processing your personal data for the provision of the Site or the Platform) which would require us to transfer your personal data outside of the UK, we will seek your consent to transfer your personal data outside of the UK. In the event of such a transfer, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity.
If you would like further information, please contact us at email@example.com.
Period for which your personal data will be stored
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.
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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting firstname.lastname@example.org.
In some circumstances you can ask us to delete your data: see Your Rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
As a result of us processing your personal data, you have a right to:
a) access personal data held about you;
b) request us to make any changes to your personal data if it is inaccurate or incomplete;
c) request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
d) receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means and is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party; or (iii) steps taken at your request prior to entering into a contract with us;
e) object to, or restrict, our processing of your personal data in certain circumstances;
f) if we use your personal data for direct marketing, ask us to stop and we will comply with your request;
g) if we use your personal data on the basis of having a legitimate interest, object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
h) to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
i) to lodge a complaint with a data protection supervisory body, which at present, is the Information Commissioner’s Office.
To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at email@example.com.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer where your request is particularly complex, in such cases, we will keep you updated of timescales. Such requests will be responded to free of charge, but a small administration fee may apply where requests are excessive.
We have put in place safeguards to prevent your personal data from being lost, used or accessed in an unauthorised way. We limit access to your personal data to those employees, agents or contractors who have a business need to know. Please contact firstname.lastname@example.org for a copy of our Security Policy.