Last Updated: 29 September 2024

LILT, Inc. and its affiliates (the “Company,” “we,” “us,” and “our”) are committed to maintaining privacy protections for users of its website (“you”) by adhering to this policy. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using and accessing our website, www.lilt.com and its associated lilt.com web pages (the “Site”) to use our translation services or other services, register an account with us, sign up to receive our blog or newsletter, or otherwise provide us with your Personal Data (together with the Site, our “Services”). 

BY ACCESSING OUR SITE OR USING OUR SERVICES, YOU ACCEPT OUR PRIVACY POLICY AND CONSENT TO OUR COLLECTION, STORAGE, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN.

If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. Please check the Site and this Privacy Policy periodically if you are concerned about how your information is used.

1. CONTROLLER

LILT, Inc. is the controller and responsible for your Personal Data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contacts details section below.

2. INFORMATION WE COLLECT

a. “Personal Data” means any information about an individual from which that person can be identified or reasonably identified. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows: 

• Identifiers and identifying data, including your name, email, phone number, billing address, username, which you may submit to us through the Site or otherwise by contacting us. 

• Financial Data and personal information listed in the California Customer Records statute, including bank account information, credit card number or other financial information, we collect this information with your consent or as otherwise permitted by applicable law.

• Commercial information, including information related to our client’s clients, and records of prior services or products purchased.

• Technical Data related to internet and network activity, including browsing or search history and information about an individual’s interaction with our Website, services or products.

• Professional or employment-related information, including your current or past job history or performance evaluations. 

• Marketing and Communications Data, including your contact preferences and your preferences in receiving marketing from us or third parties. 

• Sensitive Data, including financial data as described above and account login information. 

b. We process your information for the general performance of our Services, the operation of the Site, for marketing purposes, as necessary to comply with our legal and regulatory obligations, whenever we believe necessary to protect the vital interest of the Company, user, or of a third party, and upon your consent for a specific purpose.

c. We only keep such information for as long as necessary for the purposes set forth in this Privacy Policy, unless a longer retention period is required or permitted by law. After such period, we may either delete your information or securely store such information without further processing until deletion is possible. In no event do we have an obligation to keep your information for longer than 90 days following completion of our Services.

d. Information automatically collected via technology

In an effort to improve the quality of the Site, we track information provided to us by your browser or by our software application when you view or use the Site, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Site, the time and date of access, location data (whether precise or imprecise), current location based on IP address, settings and information about your activity on the Site (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions and features you use), device event information (such as system activity, error reports, and hardware settings), and other information that does not personally identify you.

We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. You can find more information about the Company’s use of cookies and how you can control cookies at our Cookie Policy. 

e. Information you provide us

In addition to the information provided automatically when you visit the Site, you may provide us information to get in contact with you about our services, including your name, email address, job title, company name, phone number, and location information.

You may also provide us with information if you are interested in becoming translator for the Company, you will need to submit an online application. You can submit an application on the Site by entering your name, email address, resume, and other information relevant in assisting Company assess whether you meet the requirements to be a translator. By applying, you are authorizing us to collect, store and use your information in accordance with this Privacy Policy.

f. Information collected from other sources

We may obtain information about you from other sources to enhance our ability to provide relevant marketing, offers, and services, and to update our records. This information may come from public databases, joint marketing partners, affiliate programs, data providers and other third parties, and may include name, mailing address, email address, phone number, user behavior data, IP address, social media profiles and URLs, and custom URLS for the purposes of targeted advertising and event promotion.

g. Children’s Privacy

The Site is not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at compliance@lilt.com. 

3. HOW WE USE AND SHARE INFORMATION

a. We rely on one or more of the following legal bases to process your Personal Data:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter.

b. Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Data with third parties without your consent. We may “sell” or “share” your Personal Data as those terms are defined under applicable U.S. privacy laws for cross-context behavioral (targeted) advertising. 

c. In general, the Personal Data you provide to us is used to help us communicate with you to perform a contract with you or for our legitimate interests. For example, we use Identifying Personal Data to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

d. We may share Personal Data with vendors, service providers, contractors or agents who are performing services for the Company or on our behalf and require access to such information to do that work. Such third parties use your Personal Data only at our direction and in accordance with our Privacy Policy and/or under contractual agreement. We use this data to provide translation services pursuant to a contract.

e. We may also share, on the basis of our legal obligations or legitimate interests, Personal Data with third parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable terms of service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law. 

f. We may also share your Personal Data with our affiliates, which are controlled or under common control with LILT, Inc. Any such affiliate will adhere to the terms of this Privacy Policy for our legitimate interests. And we may share your Personal Information with our business partners to offer you certain products, services, or promotions.

g. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. 

h. Automated technologies or interactions

In general, as you interact with our Site, we will automatically collect Technical Data to help us improve the Site and customize the user experience. We also aggregate Technical Data in order to track trends and analyze use patterns on the Site.  Technical Data is collected from analytics providers, such as Google based in the U.S. and advertising networks, such as Meta based in the U.S.

4. HOW WE PROTECT INFORMATION

We implement security measures designed to protect your information from unauthorized access and from potential security breaches by implementing certain technological security measures including encryption and firewalls. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By accessing our Site and using our Services, you acknowledge that you understand and agree to assume these risks.

5. YOUR RIGHTS REGARDING PERSONAL DATA

a. Depending upon where you live, you may have certain rights under data privacy or protection laws related to your Personal Data. 

b. You may have the right to: 

• Request access to your Personal Data (commonly known as a “subject access request” or the “right to know”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure/deletion of your Personal Data in certain circumstances. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it or no legal basis for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your Personal Data for direct marketing purposes (see OPTING OUT OF MARKETING for details of how to object to receiving direct marketing communications).

• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note there may be limits to this right, including that it may only apply to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of certain Personal Data under certain conditions:

• If you want us to establish the data's accuracy;

• Where our use of the data is unlawful but you do not want us to erase it;

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Or in some states, where we are processing sensitive data for a secondary purpose.

c. If you wish to exercise any of the rights set out above, please contact us at legal@lilt.com and compliance@lilt.com. 

d. Marketing Communications

You also have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

e. Opting Out of the “Sale” or “Sharing” of Personal Data for Targeted Advertising

We use cookies and similar tracking technologies that enable certain advertising networks, social media companies, analytics services, and other third-party businesses to collect and disclose your Personal Data directly from your browser or device when you visit or interact with our Site or otherwise engage with us online. 

To opt out of these “sales” or “sharing” of personal information (as these terms are defined under the CCPA or other applicable US state privacy laws), you must: [INSERT METHOD TO OPT OUT, e.g., through a cookie consent manager or submission of a form.]. 

Note that the above opt-out right does not apply where we have appropriately limited our partners to be our “service providers” or “processors” (as these terms are defined under the CCPA or other applicable US state privacy laws).

6. LINKS TO OTHER WEBSITES

As part of the Site, we may provide links to other websites, online services, or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain, nor does the inclusion of a link imply any endorsement by us. This Privacy Policy applies solely to information collected by us through the Site. This Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or to any data collected by such third parties. We encourage our users to read the privacy statements of the third party websites before proceeding to use them.

7. INTERNATIONAL TRANSFERS  

The Company’s servers are located in the United States. If you access our Site from outside of the United States, please be aware that we may transfer, store, and process your information outside of your country. We have implemented measures to protect your Personal Data, including the use of the European Commission’s Standard Contractual Clauses for transfers of Personal Information between our affiliates and between us and third party providers. These clauses require all Personal Data that they process originating from the European Economic Area or the United Kingdom in accordance with applicable data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request.  

8. DATA RETENTION

The Company will generally retain information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you are a client with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

9. CHANGES TO OUR PRIVACY POLICY

The Company reserves the right to change this Privacy Policy at any time. Any changes will be reflected as of the date written above. We encourage our users to review this Privacy Policy frequently to be informed of the latest processes with respect to your information.

10. CONTACT US

If you have any questions regarding this Privacy Policy, please reach out to us below. Additionally, you may contact us if you would like to request access to your Personal Information, change or update your Personal Information, or delete it in some cases, based upon the applicable laws and regulations of your jurisdiction. 

LILT, Inc.

ATTN: Legal and Compliance Department

2200 Powell Street, Suite 900

Emeryville, CA 94608 USA

compliance@lilt.com

legal@lilt.com