Privacy Compliance

Besteasy Privacy Information

Besteasy Co., Ltd. and its subsidiaries are committed to ensuring that we handle personal data correctly and securely. Information about appropriate security is available.

On this page, you will find a link to our privacy statement covering all our activities.

If you are a job applicant, relevant privacy information can be found in our Employee Fair Processing Notice.

For information about how we use cookies on our website, please see our Cookie Notice.

You may want to change the way Besteasy provides marketing information to you or stop receiving marketing materials by logging into our Preference Center where you can select your options.

We hope you will find all the information you need here. If you need more information or have any questions, please contact us by email: privacy@besteasy.com。

Besteasy's Privacy Policy

Besteasy treats data relating to identified or identifiable natural persons as personal data. Besteasy is keeping a close eye on Brexit developments. We will continue to comply with applicable laws that allow the transfer of personal data between the UK and the EU.

Privacy laws provide a set of rules on how organizations should use personal data, ensuring that information is securely protected, processed and stored. Besteasy is committed to complying with privacy rules.

As an organization that complies with privacy rules, Besteasy ensures that we:

◆ Treat your data fairly and lawfully ◆ Store your data securely ◆ Report any data breaches ◆ Retain your information if needed ◆ Keep a record of who has accessed your data ◆ Provide you with your data when you ask for it

Privacy Statement

This Privacy Statement explains why and how Besteasy and its subsidiaries process the personal data we receive through our websites, applications and software, through our online services, when we provide services (such as support), when we license our products, when we process inquiries about our products and services, and in any other way (for example, when we obtain your data at trade shows). These are all situations in which Besteasy is the data controller. Besteasy also provides online translation services in a number of languages. In providing these services, Besteasy is a data processor, as we explain in section 6. When processing any personal data, Besteasy aims to protect the privacy of individuals. This Privacy Statement is intended to provide transparency about the extent to which we process your data and how we process your personal data in order to enable you to exercise your right to control. Besteasy complies with the applicable laws of the territory where the processing takes place.

1.Applicability and acceptance

This Privacy Statement applies to all interactions we have with you as a data controller in connection with the collection and processing of your personal data.

◆ When you visit the Besteasy website for the first time, a cookie message will appear, informing you how Besteasy will process your personal data in the cookie. When you use the website, Besteasy will process your personal data in accordance with the terms of this Privacy Statement, a link to which is also provided on the Besteasy website. ◆ During your activities on our website, for example, when you fill out a contact form, or complete a webinar registration form, or enter a contest, or when you download a document or media file, or when you share your personal data from another social application, service or website, we will notify you that we are collecting your personal data and we will provide you with a link to this Privacy Statement. By providing your personal data or otherwise proceeding with an activity, you confirm that you have read and understood this Privacy Statement. ◆ On our website, you can register to use the various services we offer, and you can also purchase software. In order to take advantage of these services, you may need to open a user account and/or obtain an ID. The first time you use these services, a privacy message will appear and you will be asked to confirm that you understand our use of your personal data.

This Privacy Statement does not apply to the personal data of our shareholders, our employees or job applicants, or to our processing as a data processor or secondary data processor of our clients under a separate data processing agreement.

2.Children

Children under the age of 13 may visit our website and use our online translation services. Children must obtain the consent of their parent or guardian before they enter any personal data or information into the forms on our website or into our translation services. Personal data refers to your name, address, age, phone number, email address and other information that has special meaning to you. You are not allowed to provide us with personal information if you do not have the permission of your parent or guardian. All other Besteasy websites are not intended for children, and Besteasy does not knowingly collect personal information from children. If we discover that we have collected personal data from children, we will delete them as soon as possible. If you have any concerns, or believe that a child has provided us with personal data, please contactprivacy@besteasy.com。

3.Personal data

Personal data is data that you will recognize, such as your name, date of birth and address, but also includes any data that identifies you personally. This list describes the types of personal data that we collect and process from you.

◆ Email address, phone number, job title/role and IP address that allow us to interact with you during the sales process or when providing support. ◆ Data that we use to verify your identity, username, password and answers to any security questions. ◆ Depending on the services you use: financial information, such as bank account information, payment card information, billing statements and other information you provide to purchase products or services, and content you generate or that relates to your account; ◆ Technical data collected from you when you register on besteasy.com and visit the pages on our website. We use cookies (see Cookie Notice) and other methods, including statistics about your location, the type of electronic device you use, the type of operating system on your device, your connection to our website, and your use of our website.

The above list is not exhaustive, but it will give you a general idea. If we have to ask you to provide additional personal data, we will explain the reason when we ask you to provide it. We may receive information about you from other sources. ◆ We work with third parties (for example, payment service providers, credit institutions, subcontractors for technical services and marketing companies or organizations) and may receive your personal data from them. ◆ Through marketing campaigns, we may receive your personal data from corporate or social contacts. We may receive your personal data from organizations that provide contact information for company employees for business-to-business information. ◆ Our partners (which may include resellers or entities with whom we have OEM agreements) will collect personal data from their customers, which they pass on to Besteasy to enable Besteasy to license software to their customers and to enable Besteasy to provide support and maintenance.

4.Why do we collect your personal data and what is the lawful basis for our processing?

Besteasy processes your personal data as a data controller in order to fulfil our contractual obligations with you or for legitimate interests related to the delivery of our business, including the sale of products and the provision of services (free of charge and for a fee). In some cases, we may also specifically request your consent to process your personal data. The table below describes our processing and explains the legal basis on which we process your data.

5.Links to other websites

Our website may contain links to other websites that are not owned or controlled by Besteasy. Links to such other websites may open in a new browser window. Please note that Besteasy is not responsible for the privacy practices of other websites and that the operators of these websites may collect your information, which they will use in accordance with their applicable policies which may differ from ours. We encourage you to be aware when you leave our website and to read the privacy statement of each website that collects your personal data. This Privacy Statement applies only to information collected by our website.

6.If you use our online translation services

You will provide data to Besteasy for processing in the software used to provide the online translation service. Besteasy has no control over the type of data you choose to submit for processing. When Besteasy performs such processing, Besteasy is the data processor performing the processing on your behalf. When you register for these services, a specific privacy notice will appear with details of each service. Besteasy publishes the Besteasy Data Processing Agreement ("DPA") for online translation services only, which sets out the responsibilities and obligations of Besteasy as a data processor.

7.If your use of our products or interaction with Besteasy is done as an employee or consultant of Besteasy customer

If you use the Besteasy product that is licensed to your employer or an organization you are employed by, or use an email address provided by that organization, you will be identified in our records as being affiliated with that organization. Similarly, if your organization receives services from Besteasy, such as support and maintenance or localization services, and you are the point of contact for your employer, your record will be affiliated with that organization. Your use of products or services will be subject to the policies of that organization and the contract between your organization and Besteasy. Other users of your organization or authorized third parties may monitor some or all of your activities using the products and services, configure the products, including security and privacy settings, and access any data you enter. All privacy concerns related to products and services licensed to your organization should be directed to that organization.

If we have a contract to provide support and maintenance to an organization of which you are an employee, or you are engaged by that company as a consultant, that organization may provide your personal data to the extent necessary for us to interact with you for the purpose of providing service. We believe that we have a legitimate interest in processing your data for this purpose.

In the event of any conflict between this Privacy Notice and any contract or data processing agreement ("Agreement") between Besteasy and the customer, the terms of the Agreement shall prevail.

8.Who has access to your personal data and with whom do we share this data?

Within Besteasy.

Your personal data will be processed by personnel at each Besteasy company in order to fulfil the purposes for which we collected your data and to fulfil our obligations as a data controller. Details of each company can be found at Besteasy Co., Ltd.

Companies outside Besteasy.

We may share your personal data with these third parties.

◆ Industry or solution specialist partners, such as those appointed by Besteasy to sell our products in a particular industry sector or as a total solution. If we find that you are involved or interested in an industry sector or overall solution, we will pass on your personal data to our resellers or OEM partners who may contact you with details of our products and their services, etc. ◆ If Besteasy sells any business or assets, we may disclose your personal data to a prospective buyer of that business or assets, and your personal data may be one of the transferred assets. The buyer will process your personal data for the purposes of the acquisition and its business. ◆ Any other business entity that enters into a joint venture or other arrangements with Besteasy. ◆ Cookies are currently deployed on our website and further details can be found in our Cookie Notice. The provider of cookies may collect information about your use of the website. ◆ To address security or technical issues.。 ◆ If we have a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply our legal rights. This includes exchanging information with other companies and organizations for the purposes of fraud protection or credit risk reduction; and ◆ Law enforcement or regulatory authorities, if required to do so by law, or by court order.

We will not otherwise share or distribute any personal data that you provide to us without your consent.

We will not sell, trade or rent personal data to unaffiliated third parties unless we have your express permission to do so.

9.How long will we keep your data?

We will retain your information for different periods of time depending on our relationship with you and the purposes for which we collect your data. We will only retain personal data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory or internal policy requirements.

However, if you want to have your personal data removed from our database, you may make a request by using the contact information below. All requests will be considered in accordance with the circumstances set forth in Article 11 and the applicable law.

We may retain minimal items of your personal data for the purpose of recording the opt-out, including when you request the deletion of your personal data.

10.Your rights

You can control the personal data that Besteasy processes about you. You can:

◆ Withdraw your consent if at any time Besteasy obtains your consent to the processing of your personal data.

◆ Request confirmation that your personal data is being processed and request a copy of the personal data being processed. Besteasy will respond to any request to the extent required by law, and may charge a reasonable fee as required by applicable law.

◆ Obtain correction of any personal data that is inaccurate

◆ Obtain the erasure of any personal data required by applicable law. Unless requested or entitled to retain personal data, Besteasy will delete such data.

◆ Ask Besteasy to temporarily restrict its processing of your personal data while we investigate your complaint.

◆ Object to processing by Besteasy in accordance with applicable law, including profiling of you.

◆ Object to the use of your personal data for direct marketing services to you.

◆ Receive the personal data you provide to us in a structured, commonly used and machine-readable format in certain circumstances, and have the right to unimpeded transfer of that data to another data controller or, where technically feasible, transfer that personal data to another data controller.

◆ Be informed of any automated decisions made about you using your personal data and receive meaningful information about the logic involved, as well as the significance and expected consequences of such processing; and

◆ Lodge a complaint with a supervisory authority about the way your personal data is being used.

If you believe that your personal data we hold is incorrect, incomplete or inaccurate, then you may request us to correct it, or if you want Besteasy to cease processing your personal data, you may notify us of your request in the following way.

◆Send your request toprivacy@besteasy.com。

We will comply with all legitimate requests, but may refuse such requests in certain circumstances and will notify you if this applies. In some cases, Besteasy may be a joint controller of your personal data with another data controller. For example, we work with a partner, etc. If Besteasy is a joint controller, we will be responsible for the personal data we hold and process. For personal data held by Besteasy, you can exercise our rights as explained above, such as requesting deletion, by making an inquiry to Besteasy using the contact details below. If you wish to exercise your rights against other joint controllers, you can do so by contacting them.

11.How Besteasy protects your information

◆ Besteasy ensures that its privacy statement complies with all applicable privacy laws and regulations.

◆ Besteasy and its subcontractors will maintain appropriate security procedures and practices to safeguard the products and your data from unauthorized access and to maintain the confidentiality of your data in accordance with applicable law. We employ strict physical, electronic and administrative security measures to protect your information from unauthorized access and to prevent unlawful processing, accidental loss, destruction and damage, both online and offline. Data is encrypted as it travels between your device and Besteasy's systems, and our products are hosted in third-party data centers with industry-leading security.

◆ The Internet itself is an open and insecure means of communication, and any data transmitted by users over the Internet can be intercepted and altered. Besteasy does not guarantee and is not responsible for the security and integrity of any data you transmit over the Internet, including any data transmitted through any server designated as "secure". You should have no expectation of privacy with respect to any content, including accounts of files transmitted over the Internet.

No website can be completely secure. If you are concerned that your Besteasy.com account may have been compromised, please contact Besteasy using the contact information below.

12.Changes to our Privacy Statement

Any changes we make to this Privacy Statement will be posted on this page and will be effective 28 days after posting. You should bookmark this page and check it regularly to ensure that you are familiar with the latest version of this Privacy Statement.

13.Complaints

If you are dissatisfied with the way your personal data is handled by Besteasy, please contact the centralized privacy response (privacy@besteasy.com). You may want to contact individual Besteasy company, but please note that all responses are handled centrally via privacy@besteasy.com.

Cookie Policy

Our website uses cookies to provide you with relevant information when you visit and use our website, to make it easier for you to log in, help you navigate between pages of our website, and help provide a focused and enhanced experience when you browse our website. By monitoring the use of our website, we ensure that advertisements are more likely to be relevant to you and provide us with information to help us improve our website. This Cookie Notice explains our use of cookies in the event that you: ◆ Visit one of our websites or any other website we add ("Website") or create an account or use the services offered on our website. Download, install or otherwise use any Besteasy software product, including any demos in connection with such products ("Products"); or ◆ Subscribe to, access, configure or otherwise use any hosted or Software-as-a-Service product ("SaaS Product"). We explain the following in this Cookie Notice (Section 5. Managing Your Use of Cookies). You have the option to manage or disable cookies using the Cookie Settings Link displayed at the bottom of the page. If you choose to disable cookies, some parts of our website may not function for you fully or at all. We offer a Cookie Preference Center, which operates independently on each website. If you would like to adjust your cookie settings, please visit the Cookie Preference Center or the Cookie Settings Link at the bottom of each website page.

1.Definition of cookies

A cookie is a small file, usually consisting of letters and numbers, that is downloaded to a device (computer or cell phone) when you visit certain websites. Each time you use your device to visit our website, your device sends data from the cookie file to our website that allows our website to recognize the device that is connecting to our website. This data may be a unique identifier, user preference and profile information, and membership information. This allows Besteasy to recognize your preferences and store them in order to provide services more efficiently on your subsequent visits.

Cookies do not allow us to access your device.

2.Information we may collect about you

We may automatically collect the following information each time you visit our website.

◆ Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone settings, browser plug-in type and version, operating system and platform; and

◆ Information about your visit, including the full Uniform Resource Locator (URL) clickstream (including date and time) into, through and out of our website, products you viewed or searched for, page response times, download errors, time spent visiting certain pages, page interaction information (such as scrolling, clicks and mouse movements), and the methods used to navigate the pages.

We do not collect your name, address, phone number, or email address.

The information we collect is used to create user profiles for devices connected to our website and is used only in connection with the use of the website.

3.Contact us

If you have any questions or concerns about Besteasy's use of cookies or this notice, you may contact us at privacy@besteasy.com.

4.Privacy

Further information about Besteasy's use of personal data can be found in our Privacy Statement.

5.Changes to the Notice

Any changes we make to this Notice will be posted on this page and will take effect 28 days after they are posted. You should bookmark this page and check it regularly to ensure you are familiar with the latest version of this Cookie Notice.

Besteasy Language Cloud Privacy Policy

Besteasy Language Cloud Privacy Statement Besteasy's privacy statement located here describes how Besteasy uses your information when you use Besteasy's websites, products and services. This Besteasy Language Cloud Privacy Policy describes the practices specific to this website and the services offered herein.

1.Information Besteasy collects when you use Besteasy Language Cloud

◆ Personal information provided by you. Besteasy, as a data controller, will collect the information necessary to create an account to use the services and payment information, such as your name, email address, mailing address, phone number, and credit card number.

◆ Anonymous Information. Anonymous information does not personally identify you. It may be provided voluntarily or collected automatically and includes log information, browser and device information, information collected through cookies, and general statistical information.

◆ Order content. Besteasy will only process the information submitted or generated as part of an order, such as source materials, corresponding translations or other similar information, as a data processor. For any personal data contained in the source materials, the customer will be the data controller.

2.How Besteasy uses this information

◆ To personalize your experience. Personalization may include providing content that is tailored to your interests, such as targeted banners, new services and promotions.

◆ To process your transactions and orders.

◆ For contact and notification purposes. This may include sending newsletters, marketing or other promotional materials.

◆ For auditing and conflict resolution. This may include contacting users regarding inappropriate use of Besteasy products and services, non-compliance with any terms and conditions of use, or complaints filed by other users.

◆ For the development, operation and improvement of Besteasy's products and services. This may include contacting users to participate in market research and/or collecting certain anonymous statistics and data to improve the user experience.

3.How Besteasy uses source materials

◆ In order to provide the services ordered. Besteasy states that no source material will be required, stored or used by Besteasy's translation engine during the machine translation process, other than the terminology dictionaries that will be stored securely.

4.Security

◆ Besteasy will take reasonable efforts to protect your information from unauthorized access.

◆ The source material will not be disclosed to third parties. Your terminology dictionary is for your personal use only and will not be shared with other users of the Besteasy Language Cloud.

◆ Besteasy may provide access to your information if Besteasy believes in good faith that such disclosure is reasonably necessary to (1) comply with any applicable law, regulation or legal process, (2) detect or prevent fraud, and (3) address a security or technical issue.

Our privacy policy may change over time. We will post any privacy notice changes on this page. Our privacy practices are described in the full privacy notice located here.

MT Privacy Policy

Policy for maintaining the confidentiality of customer data

When using the MT Engine, Besteasy understands that the security and confidentiality of your data are of the utmost importance to you. The information below details how we protect the data you submit to the MT Engine for translation.

What happens to your source files and the resulting translations?

◆Data is translated by the MT Engine. Besteasy does not retain copies of source files or translated materials. Your data is not shared with or used by any other customers. ◆ The statistical model generated by the MT Engine is unique to you and is stored in your MT Engine and is not accessible to any other client. The statistical model includes various statistical information related to the co-occurrence of the source and target words. ◆ The MT Engine is hosted in a third-party data center. Further details are as follows.

Data Security Policy

◆ Besteasy and its subcontractors will maintain appropriate security procedures and practices to protect the product and your data from unauthorized access and to maintain the confidentiality of your data in accordance with the applicable law. Data will be encrypted as it travels between your device and Besteasy's systems, and our products are hosted in third-party data centers with industry-leading security.

◆ The Internet itself is an open and insecure form of communication, and any data transmitted by users over the Internet may be intercepted and altered. Besteasy does not guarantee and is not responsible for the security or integrity of any data you transmit over the Internet, including data transmitted through any server designated as "secure". You should have no expectation of privacy with respect to any content, including accounts of files transmitted over the Internet.

Permissible uses and personal data

◆ Besteasy provides the MT Engine for your use in compliance with all applicable laws, rules and regulations, codes of conduct (including voluntary codes of conduct), guidelines, instructions, policies and/or other requirements, including but not limited to all applicable state, federal, national and international Internet, data, telecommunications, marketing, telemarketing, "spam" and import/export laws, regulations and procedures adopted from time to time. You acknowledge that by providing you with access to the MT Engine, Besteasy will act as a passive conduit for your activities and that Besteasy will not assume any obligation or liability in connection with your activities.

◆ Besteasy has no control over the nature of the data you will submit for translation. Besteasy's processing is limited to providing the MT Engine and related infrastructure.