Last updated: September 29th, 2020
Welcome to this website or mobile application, a service of iTranslate GmbH and its corporate affiliates (collectively, “iTranslate”, “we”, “us” or “our”). This Privacy Policy (“Privacy Policy”) explains how we collect, create, use, process and share personally identifiable information in our iTranslate Medical mobile applications and related online services (“iTranslate Medical”), or any other website, mobile application or interactive features that link to this Privacy Policy. This Privacy Policy also explains the rights and choices available to individuals whose personal information we collect, create, use, process or share in iTranslate Medical.
Please note, this Privacy Policy constitutes an “in-time” notice that supersedes iTranslate’s general Privacy Policy with respect iTranslate Medical. We may provide additional privacy notices to you at the time we collect your data. This type of “in-time” notice will govern how we may process the information you provide at that time.
IMPORTANT. Under this Privacy Policy, “you” means individuals that download iTranslate Medical. For iTranslate Medical, we have implemented specific measures to safeguard the privacy of user-generated content out of concern for the privacy of users who wish to share personal information in a medical context. Translations are only available while you are using the application. We restrict the persistence of translations and personal information that you collect while using the application, restrict the processing of language translations to the portable device on which you download iTranslate Medical, disable transcription and sharing features, and prevent user-generated content from being transmitted to our cloud-based services (except for purposes of improving product performance and functionality). We believe these measures will increase individuals’ trust in using iTranslate Medical to share their highly personal information with their medical providers. Necessarily, by implementing these safeguards, we cannot detect what you do with the personal information that you collect from patients or other third parties.
You can read this policy from top to bottom, or use these links to read specific sections that describe our privacy commitments to you.
California residents may click here for Your California Privacy Rights
Click on the links below to jump directly to sections of the Privacy Policy:
iTranslate Medical is designed to limit the collection of personal information during usage. Translations are only available while you are using the application and they remain on the device only and are not stored. We prevent user-generated content from being transmitted to our cloud-based services (except for purposes of improving product performance and functionality) when you collect two basic types of information from users: personal information and non-personal information.
Personal Information may include data that is unique to an individual, like your name, e-mail address and content that individuals create in the application to generate language translations (“user-generated content”). It can also include information which is not unique to any natural person but which may become associated with the copy of iTranslate Medical that you use. For example, personal information may include: (1) commercial information (for example, the identity of an organization that licenses your copy of iTranslate Medical and authorizes your right to download, access and use the application, and related purchase information and contract terms), or (2) usage data (such as web browser information, server log files, cookie technology, pixel tags or beacons, and other technologies), which we collect to monitor performance and conduct business analytics. Non-Personal Information means information that does not identify you personally and cannot reasonably be associated, reidentified or linked back to you or your household. Examples include usage data that may have started as personal information but which has been stripped of identifiable factors in a way that prevents it from being re-associated, re-identified or linked back to you or others. For more information, see Information Collected by Automated Means.
The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR”). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.
Categories of personal information we collect:
Some of this information you provide to us and some we collect when you use iTranslate Medical. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others. You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing iTranslate Medical to you or limit our ability to provide you with the level of service that you would otherwise expect from us.
Information collected from you
The following are examples of the types of information you choose to give us when using our iTranslate Medical:
Information collected by automated means (“Automated Information”)
We collect Automated Information through the use of cookies, SDKs and other technologies. Please see our Cookies Policy for more information on cookies. On our websites we offer users the option to disable receiving certain types of cookies via our privacy preference centre; however, if cookies are disabled, some features or functionality of our websites may not function correctly.
Automated Information includes information such as:
We or our third-party service provider may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy.
This Automated Information is generally used for the following purposes:
Information collected from integrated services.
We may obtain information, including personal information from third parties and sources that we integrate into iTranslate Medical either for the provision of iTranslate Medical or to facilitate your access to iTranslate Medical such as described below.
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:
To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
We may share information about you for the purposes described in this Privacy Policy or pursuant to a specific “in-time” privacy notice we may provide at the time we collect the information.
Corporate Affiliates
iTranslate is part of the IAC Group family of businesses. We may share your information with other parts of IAC for legitimate business purposes, including:
Third Party Service Providers
We consider all data that we collect to be confidential. We use third party service providers, including corporate affiliates, to assist us in delivering iTranslate Medical to our customers. We share data with these third parties, to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep our data confidential and are only authorized to use it for specific purposes. We always seek your approval before exchanging personal information with third party services that link your accounts with them to your iTranslate Medical account.
Following is more information about the specific categories of third-party service providers with which we may share personal information, and reasons for sharing that information:
Corporate Transactions
We may share information about you in connection with (including during the evaluation or negotiation of) a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind-down of a business (each a “Corporate Transaction”). Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we engage in any Corporate Transaction (including, selling or transferring all or a portion of our business or assets). If we engage in such a sale or transfer, we will where feasible - direct the recipient to use the information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
Legal, Regulatory, Compliance and Similar Reasons
In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.
We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us.
In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.
Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our sites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.
Your Choices and Rights.
As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:
If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may contact us here. Be advised: Because of the privacy-preserving features of iTranslate Medical described in the introduction to this Privacy Policy, personal information does not persist in the iTranslate Medical mobile app or on iTranslate information systems, with the limited exception of account information. Moreover, users are not required to create an iTranslate Medical account to use the mobile app. For these reasons, we will be unable to process most requests to exercise the rights described in this Section. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with iTranslate Medical or some of its features and functionality. In addition, you may contact us here to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors). Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
For your protection, we may require proof of identity and verification before we can answer the above requests.
Legal basis for processing data
In this section, we identify the legal grounds on which we rely to process personal information.
In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition).
In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.
It may be also necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the iTranslate Medical services we provide.
Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting. We may also process personal information as specifically permitted by applicable legal requirements. If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
We may also process personal information as specifically permitted by applicable legal requirements.
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
International data transfers
We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Policy. For example, if you are located outside of the United States, we may transfer your personal information to the United States, where IAC Group is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.
Specifically, we may transfer personal information from the European Economic Area to:
If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy. The CCPA Notice applies to “Consumers” as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights. Be advised: Because of the privacy-preserving features of iTranslate Medical described in the introduction to this Privacy Policy, personal information does not persist in the iTranslate Medical mobile app or on iTranslate information systems, with the limited exception of account information. Moreover, users are not required to create an iTranslate Medical account to use the mobile app. For these reasons, we will be unable to process most requests to exercise the rights described in this Section.
Access to Information and Data Portability Rights
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.
Data Deletion Rights
Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.
Exercising Your Rights
To make a request for access, portability or deletion according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to iTranslate GmbH, 330 West 34th St., 5th Floor, New York, NY 10001. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”).
The Verifiable Consumer Request must:
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your personal information as defined by the CCPA.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address).
To find out more about our “do not track” practices under Cal. Bus. & Prof. Code § 22575, see the Do Not Track Disclosures section of this Privacy Policy.
Access, Edit and Delete Your Information.
If you are a resident of the EEA, your rights to access, edit and delete your information can be found in the Information for Individuals in the European Economic Area (EEA) section of this Privacy Policy. If you are a California resident, your rights to access, edit and delete can be found in the Information for Residents of California: Your California Privacy Rights section of this Privacy Policy.
As described in the introduction to this Privacy Policy, none of your user-generated information persists in the iTranslate Medical mobile app or on iTranslate information systems. For this reason, we are unable to process requests to access, correct and/or delete personal information that you provide to iTranslate Medical.
Device permissions
Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Uninstall
You can stop all information collection by the app by deactivating your account (where applicable) by following the instructions on iTranslate Medical’s Settings screen or uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we may be able to re-associate this identifier to your previous account.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by the applicable mobile application support email. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding iTranslate Medical.
Location information
If you choose to opt-in, some of our apps may collect your device’s precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device.
Notice to Nevada users
Under Nevada law, Nevada residents may opt out of the “sale” of certain “covered information” (as defined under Nevada law) collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by Nevada law, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.
International Transfers
iTranslate Medical is hosted in the United States. If you choose to use iTranslate Medical from outside the United States, with laws governing data collection and use that may differ from United States law, note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may transfer your data from the United States to other countries in connection with the storage and processing of data to operate our business. By using iTranslate Medical and providing personal information, you consent to such transfer, storage and processing. If you are a resident of the EEA, you can learn more about transfers outside the EEA in the Information for Residents of the European Economic Area section of this Privacy Policy.
Marketing Opt-Outs
Some of the service providers that we use to market our Services and show our ads on other websites and mobile applications may participate in the Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising on the websites and mobile applications that you visit and use, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA's opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.
When you allow Notifications, we may send you offers, and promotions related to our products and features. You may opt-out of these through the Settings menu on your device.
User-generated content is not transmitted from your device to iTranslate Medical’s cloud-based services. If you are a consumer that has used iTranslate Medical on a device controlled by another person, your personal information is governed by that person’s data retention policies. Except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using iTranslate Medical or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using iTranslate Medical so we encourage you to contact us if you are no longer using iTranslate Medical. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.
We use various efforts intended to safeguard the security and integrity of personal information collected through iTranslate Medical. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you collect personal information with iTranslate Medical at your own risk.
If you correspond with us by e-mail or using Web forms available through iTranslate Medical, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using iTranslate Medical, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.
If we believe that the security of any personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.
We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE iTRANSLATE MEDICAL. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.
We reserve the right to change this Privacy Policy at any time. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Policy. In some cases (for example, if we make certain material changes) and when required by applicable law, we may inform you by additional means, such as by sending you an email (if we have your email address) In some cases, when required by applicable law, we may obtain your consent to the changes.
You may contact us with questions, comments, or concerns about iTranslate Medical and this Privacy Policy or our privacy practices, or to request access to or correction of your information by submitting your requests or inquiries as detailed below:
For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached here.
If you are a resident of California, please contact us here.
Our support team can be contacted medicalitranslate.com.
OR
Without prejudice to any other rights you may have, if you are located in the EEA, you also have the right to file a complaint against iTranslate with the Austrian Data Protection Commissioner ("DPC"), which is iTranslates Lead Supervisory Authority. The DPC’s contact details are:
If you live in the EEA, you may also file a complaint with your local data protection regulator.
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