SDL PRIVACY POLICY
FOR USERS OF OUR WEBSITES

This Privacy Notice explains why and how SDL PLC and its subsidiaries (“SDL”) over our websites and through Apps collect and process your Personal Data. SDL is the Data Controller for Personal Data Collected through the SDL websites. SDL Global Solutions (Ireland) Ltd is the Data Controller for Personal Data collected through our on-line shopping activity.

SDL’s objective is to provide our visitors with a quality online experience whilst safeguarding your privacy.

Personal Data is data you would recognise such as your name, date of birth and address but also any data from which you can be personally identified. We ask you to provide some Personal Data and we also automatically collect some of the Personal Data when you register on SDL.com and when you visit pages on our websites. 

This list describes the types of data we collect from you and process:

• email address, phone number, mobile telephone number and IP address;
• data we use to verify your identity username, passwords and answers to any security questions;
• depending on the services you use: financial information, such as bank account details, Payment Card Details, billing and other information you provide to purchase a product or services and content you generate or that relates to your account; 
• technical data is collected from your use of our sites we use cookies (see Cookie policy) and other methods including information about your location, the type of electronic devices you use, the type of operating system on your devices, on the connection you have with our websites and statistics on your use of our websites; and
• from information you provide to us through correspondence, SDL communities, chats, dealing with any complaints, or shared by you from other social applications, services or websites. 

The above list is not exhaustive but gives you a general picture. If we have to ask you to provide more Personal Data we will explain why when we ask for it. 

We collect personal data from you when you complete a contact form, or create an SDL account or complete a registration form for a Webinar or enter a competition or when you download documents or media files, or when you sign up for communities or purchase products or services or when you log into a Live Chat session. 

We may receive information about you from other sources: 

• We work with third parties, (for example, payment services providers, credit agencies, sub-contractors in technical services and marketing companies) and may receive Personal Data from them about you. 

Our site may contain links to other websites that are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided, the operators of those websites may collect information from you which will be used by them in accordance with their Privacy policy, which may differ from ours.

SDL processes your Personal Data either to perform our contractual obligations with you or for legitimate interests associated with the delivery of our business, including sale of products and provision of the services (both free of charge and charged) offered on our websites. We may also specifically ask for your consent for processing of your Personal Data in some cases. The table below describes our processing and explains the lawful basis we rely upon to process your data:

• To enable you to participate in interactive features of our sites; 
• To ensure that content is presented in the most effective manner for you and for your computer; 
• Maintain the security of our sites and services; 
• Deliver relevant advertising to you about our products and services and measure the effectiveness of our marketing; and 
• Administer our sites through data analysis, testing and support. 

SDL considers this processing of your data is based upon the lawful basis of our legitimate interest to administer our site and provide you with relevant information about our products and services.

Within the SDL Group of companies: 

Your personal data will be processed by our staff in the SDL group of companies which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, to complete the purposes for which we collect your data. 

Outside the SDL Group of companies: 

We may share your Personal Data with these third parties: 

• As SDL does not have offices in all countries we have appointed Resellers in some countries who sell our products. If we identify you are logging into our website from such a country we will pass your personal data to our Reseller or OEM partner to provide you with an ability to obtain details etc. about our Products; 
• Similarly if we identify you are involved in or interested in an industry sector or in a total solution offering where SDL has appointed industry or solution specialist Resellers or OEM partners to sell our products, we will pass your personal data to our Reseller or OEM partner who may contact you to provide you with details etc. about our Products and their services;. 
• With organisations we engage as agents or sub-contractors to perform functions on our behalf such as sending customer communications, analysing data, providing marketing assistance, processing payments and providing customer service. They will have access to Personal Data needed to perform their functions, but may not use it for any other purposes; 
• If SDL sells any business or assets, we may disclose your Personal Data to the prospective buyer of such business or assets and your Personal Data may be one of the transferred assets; • If SDL is acquired by a third party, your Personal Data will be one of the transferred assets; 
• If SDL enters into a joint venture with another business entity, we may disclose your Personal Data to the other business entity; 
• Our sites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use our Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our Site, compiling reports on website activity for internet operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using our Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. In order to distinguish one visit from another, Google Analytics may create several tracking cookies on a visitor’s computer which will expire after two years have passed since the initial visit; 
• To address security or technical issues and 
• If we are under 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 organisations for the purposes of fraud protection or credit risk reduction; and 
• If required to do so by law to law enforcement or regulatory agencies or by an order of a Court. 

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the European Union (“EU”) and European Economic Area ("EEA"). It may also be processed by staff operating outside the EU and EEA who work for us or for one of our suppliers. By submitting your information, you agree to this transfer, storing and or processing. 

We will take all steps reasonably necessary to ensure that your information is processed securely. A copy of the applicable documentation ensuring the necessary safeguards can be obtained from SDL using the Contact details below; and We will not otherwise share or distribute any of the information you provide to us without your consent. We will not sell, trade or rent Personal Data to unaffiliated third parties except if we have obtained your express permission.

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

However, if you wish to have your personal data removed from our databases, you can make a request using the Contact information in the section below.

You are in control of the Personal Data SDL processes and you can: 

• If SDL has obtained your consent to processing your Personal Data withdraw your consent at any time; 
• Request confirmation your Personal Data is being processed and a copy of the Personal Data being processed. SDL will respond to any request to the extent required by law and may charge a reasonable fee as provided by applicable law; 
• Obtain rectification of any inaccurate Personal Data; 
• Obtain the erasure of any Personal Data as provided by applicable law and SDL will erase unless required or entitled to preserve the Personal Data; 
• Request SDL to temporarily restrict its processing of your Personal Data while we are investigating a complaint you have; 
• Object to processing by SDL as provided by applicable law including profiling of you; and 
• Object to your Personal Data being used for direct marketing services to you. 

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it or you want SDL to stop processing your personal data you can inform us of your request by either: 

• Using the SDL Preference Centre is available at https://info.sdl.com/preferences.html. for you to change your own preferences and details in respect of marketing communications. 
• Contacting your normal contact at SDL. 
• Emailing your request to privacyrequest@sdl.com 

We will comply with all lawful requests but can refuse such requests in certain circumstances which you will be informed of if they apply.

• SDL ensures that its Privacy Policy is in compliance with all applicable privacy laws and regulations. 
• SDL complies with the EU-US Privacy Shield and Swiss-US Privacy Shield as set by the U.S Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. SDL INC has certified that it adheres to the EU-US and Swiss-US Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the EU-US and Swiss-US Privacy Shield program and to view SDL INC’s certification, please visit https://www.privacyshield.gov/list. 
• SDL and its subcontractors will maintain appropriate security procedures and practices to safeguard the product and your data against unauthorized access and to maintain the confidentiality of your data in accordance with the applicable law. We employ strict physical, electronic and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line. The data is encrypted when in transit between your device and the SDL system and our products are hosted in third party data centres with industry leading security. 
• The Internet is an inherently open and insecure means of communication, any data a user transmits over the Internet may be susceptible to interception and alteration. SDL makes no guarantee regarding, and assumes no liability for, the security and integrity of any data you transmit over the Internet, including any data transmitted via any server designated as "secure". You should not have an expectation of privacy in any content, including accounts of files transmitted through the internet. 

No website can be completely secure. If you have concerns your SDl.com account may have been compromised please contact SDL using Contact below.

If you are unhappy with the way SDL is processing your Personal Data please contact the Privacy Officer, using the Contact Details below. 

You also have the right to lodge a complaint with the relevant Supervisory Authority responsible for overseeing the processing of Personal Data. 

For SDL PLC this is: 

The Information Commissioners Office (ICO) 

Website: www.ico.org.uk 

Postal Address: 

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number 

Fax: 01625 524 510 

Email: Please see ICO website 

For SDL Global Solutions (Ireland) Ltd this is: 

Data Protection Commission Website: http://gdprandyou.ie/ 

Postal Address 

Data Protection Commission
21 Fitzwilliam Square, Dublin 2, D02 RD28, Ireland 

Tel: +353 (0)761 104800 

Email: info@dataprotection.ie

If you have any questions, comments or concerns about the Privacy Policy, please contact us as follows: 

Email at: privacy@sdl.com

Mail: 

FAO: Privacy Officer (Legal Department)
SDL PLC
New Globe House
Vanwall Business Park
Vanwall Road
Maidenhead
Berkshire
SL6 4UB
TEL: + 44 (0) 1628 760610
Fax: +44 (0) 1628 760611 

SDL PLC is a company registered in England with registered number 02675207 of New Globe House, Vanwall Road, Vanwall Business Park Maidenhead, Berkshire, SL6 4UB, United Kingdom, and includes all its affiliate and subsidiary companies and entities.

Last updated: August 2018