1.1 The Go Translate mobile application (the "App") is provided to you by HiClub Inc ("HiClub", "we", "our", or "us"). The App allows you to perform translations of voice, text and photograph content to and from certain languages (the "Service").
1.2 We are committed to protecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information").
1.3 Please ensure that you have read this privacy policy and understood how we collect, store and disclose your personal information before you access or use the Service.
2.1 HiClub is the controller of the personal information we collect about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.
3.1 We collect personal information when you voluntarily submit information directly to us when you use the Service. This can include the content you provide to us for translation through the Service, information you provide to us when you correspond with us by phone, e-mail or otherwise, or when you use some other feature of the Service.
3.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide those parts of the Service to you or respond to your other requests.
3.3 The following table sets out the categories of personal information that you submit to us when you use the Service and how we use that information. It also sets out the lawful basis we rely on for processing that personal information:
| Category of personal information | How we may use it | Legal basis for processing |
|---|---|---|
| The content you submit to the Service for translation. The text, photos and voice (via your device’s microphone) you submit to the Service when you use the translation function on the Service. When you use the voice content translation functionality of the Service, we will convert the recording into text using the applicable functionality of the Service. | We use this information to provide you the translation functionality of the Service. | The processing is necessary for the performance of a contract between you and us. |
| We use this information to test and improve the Service | The processing is necessary for our legitimate interests, namely developing and improving the Service | |
| Translated content. The translation of the content you submit to the Service when you use the translation function on the Service. | We use this information to test and improve the Service, including improving the accuracy of the translation function on the Service and developing new features and functionalities. | The processing is necessary for our legitimate interests, namely developing and improving the Service. |
| We use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely informing our marketing. | |
| Your location. We will ask to collect your location when you first access the Service. You do not have to agree to provide your location to us, and you can stop sharing your location at any time by adjusting the settings on your device. | We use your location to suggest the appropriate local language into which your content may be translated through the Service. | We will only process the information in this way if you give us your consent to do so. |
| Your comments and opinions.When you contact us directly, such as by email, phone, post or by completing an online form, we will record your comments and opinions. We may also record your responses or submissions to us when you respond to a survey, enter a competition or take part in a promotion that we run. | We use this information to address your queries, issues and concerns and improve our products and services. | The processing is necessary for our legitimate interests, namely providing customer support. |
| We use this information to help us improve the Service, including developing new features and functionalities. | The processing is necessary for our legitimate interests, namely developing and improving the Service. | |
| Your preferences:We hold information about the preferences you set for notifications, marketing communications and how our App is displayed. | We use this information for providing notifications, sending marketing communications and displaying our Service in accordance with your choices. | The processing is necessary for our legitimate interests, namely providing the functionalities and features of the Service to you in accordance with your preferences. |
3.4 We also collect personal information from you indirectly such as information about how you use the Service and the mobile device you use to download the App.
3.5 The table below sets out the categories of personal information we collect about you automatically when you download the App and use the Service and how we use that information. It also sets out the lawful basis we rely on for processing that personal information.
| Category of personal information | How we may use it | Legal basis for processing |
|---|---|---|
| Information about how you access and use the Service. For example, how frequently you access the Service, the time you access the Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service. | We may use information about how you use and connect to the Service to present the Service to you on your device. | The processing is necessary for our legitimate interests, namely to tailor the Service to the user. |
| We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | |
| We may use this information for statistical purposes, to monitor and improve the Service and business, resolve issues and to inform the development of new products and services. | The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Service and to improve the Service generally. | |
| Log files and information about your device.We also collect information about the tablet, smartphone or other electronic device you use to download the App and connect to the Service. This information can include details about the type of device, unique device identifying numbers, operating systems and applications connected to the Service through the device, your mobile network, your IP address and your device’s telephone number (if it has one). | We may use information about how you use and connect to the Service to present the Service to you on your device. | The processing is necessary for our legitimate interests, namely to tailor the Service to the user. |
| We may use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | |
| We may use this information for statistical purposes, to monitor and improve the Service and business, resolve issues and to inform the development of new products and services. | The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Service and to improve the Service generally. |
3.6 We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our App and the Service and developing new products and features.
4.1 We may share your personal information with the following parties:
4.2 We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our Service but we will make sure no one can be identified from this information before we disclose it.
5.1 From time to time we may contact you with information about our products and services. For some marketing messages, we may use personal information we collect about you to help determine the most relevant marketing information to share with you. We, or we may allow third parties to deliver certain targeted advertising about products and services that we or they believe may be of interest to you based on information about how you use the App and data associated with your device via mobile advertising platforms.
5.2 We may share information relating to the device you use to access the Service with third parties for this purpose. The information we share can include the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Service and information about which adverts you have seen or clicked on.
5.3 We and our third party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you use the Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
5.4 Most marketing messages will be in the form of App push notifications. If you do not want to receive marketing messages, you can change your marketing preferences by adjusting the system settings on your device.
5.5 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).
5.6 To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
5.7 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
5.8 Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.
6.1 Security: we implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage.
6.2 International Transfers of your Personal Information: the personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside of the EEA. Some of these jurisdictions offer differing levels of protection in respect of personal information and may, in certain instances, be less protective than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy. If you wish to find out more about the safeguards we use, please contact us using the details set out at the end of this privacy policy.
7.1 If you are based in the EU, the EEA, the UK or Switzerland, in accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:
7.2 You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
7.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.
7.4 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
7.5 We will seek to respond to any request relating to your rights within one month of receipt of such request.
7.6 Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the extended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an extension is required.
7.7 Where we do not follow up on your request, we will inform you within the one month deadline of the grounds on which we have based our decision and of you right to refer a complaint to your national data protection authority.
Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
9.1 Our Service is not directed at persons under 13 and we do not knowingly collect personal information from children under 13. If you become aware that your child under 13 has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove delete this information.
We may update this privacy policy from time to time and so you should review this policy periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
12.1 Questions, comments and requests regarding this privacy policy are welcome and should be addressed to GTfeedback@creativeappnow.com.
12.2 If we are unable to deal with any issues you raise with us, you may also have the right under applicable law to lodge a complaint with your national data protection authority. If you are in the EEA or UK, further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Last Modified: July 2, 2019