Privacy Policy

Last Updated: July 30, 2009

1. Scope of application

This Privacy Policy establishes how we handle the information we obtain about you when you use the Services (as such term is defined in the SYSTRANet Terms of Service) provided by SYSTRAN and/or its Subsidiaries and Affiliates (as such term is also defined in the SYSTRANet Terms of Service), hereinafter collectively referred to as "SYSTRAN". Protecting the privacy and Personal Data of our users is of utmost importance to SYSTRAN.

Unless otherwise defined in this Privacy Policy, capitalised terms shall have the meaning ascribed to them in the SYSTRANet Terms of Service.

2. Nature of information gathered, tracked or used by SYSTRAN

The information in relation to you which is gathered, tracked or used by SYSTRAN through your use of the Services is of two different types: 1) Personal Data you voluntarily supply when you subscribe, order, complete a form, register for certain Services or provide your e-mail address, and 2) non-personally identifiable information, which includes tracking information collected as you navigate through our Services (collectively "Collected Information").

A. Tracking information and use of cookies

Some of SYSTRAN's Services are using cookies. Cookies, by themselves, are not able to extract any Personal Data from you. This cookie automatically identifies your computer - but not you - to SYSTRAN's servers when you visit SYSTRAN's websites. Unless you specifically tell SYSTRAN, SYSTRAN will never know who you are, even though we may assign your computer a cookie.

The only information SYSTRAN automatically collects is the tracking information related to the use of its Services. This information is anonymous and is gathered through SYSTRAN's servers' log files. These log files record generic information, such as the number of visits our web site receives, the types of browsers used and the number of files downloaded, but never Personal Data.

B. Personal Data

SYSTRAN does not collect information that personally identifies you as an individual except when you provide such specific information on a voluntary basis. There may be occasions where specific Personal Data are requested before you can enter certain sections of SYSTRAN's website or as part of the registration process for the Services, or as part of your continued use of the Services. In all such cases, SYSTRAN will collect only Personal Data that is voluntarily provided by you and undertakes that such information will be kept strictly confidential.

3. Consent to processing by SYSTRAN of your Personal Data

By returning or submitting a form with your Personal Data to SYSTRAN, you consent to:

• SYSTRAN processing your Personal Data for the purposes described in clause 4 below; and
• SYSTRAN transferring your Personal Data to countries which do not provide the same level of data protection as France for the purposes described in clause 4 below.

4. Use by SYSTRAN of Collected Information

A. Anonymous information

The log file information allows SYSTRAN to attempt to better target your preferences.

Cookies allow us to personalize the relevant Services for you and to provide you with information that fits your needs and desires. For instance, once you register for a Service online, a cookie is written to your computer so that you will not need to type information (such, for instance, as a password) in the future to obtain support.

Anonymous Collected Information obtained through log files and cookies is used and analyzed only at an aggregate level to help SYSTRAN understand subscribing and purchasing patterns trends and patterns and to perform statistical analyses so as to improve the Services or to gather marketing information. SYSTRAN also uses anonymous Collected Information for Services' development purposes and to generally inform advertisers about the nature of its user base. We also use Collected Information to allow advertising to be targeted, in aggregate, to the users for whom such advertising is most pertinent.

If you do not want anonymous Collected Information used in this manner, you can disable or delete the cookies on your computer.

B. Personal Data

Personal Data is used by SYSTRAN to attempt to better meet your needs, inform you of new Services, target and provide personalized offers and Services that SYSTRAN knows you may be interested in.

If you do not want your Personal Data used in this manner, you can opt-out during the registration process or change your account information.

5. SYSTRAN's obligations in relation to Personal Data

Any Personal Data you submit through SYSTRAN's websites will be held in the strictest confidence. To ensure this, all forms on our websites that send Personal Data to a database that may be used in the future, e.g. mailing lists, registration, etc., have check boxes where you specify whether or not you would like to receive information from us in the future. Forms used just to send emails, post messages, etc., do not include the option, but will never be used to send information. If you choose to receive information from us, each message will also include instructions on how to "unsubscribe" from future mailings should you wish to cancel.

SYSTRAN complies with the principles of the European Parliament and Council Directive 95/46/EC of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and with the provisions of French law n°78-17 dated 6 January 1978 regarding IT, files and freedoms, as amended by French law n°2004-801 dated 6 August 2004.

SYSTRAN has given prior notice to the Commission Nationale de l'Informatique et des Libertés (National IT and Freedoms Commission) of the processing of Personal Data and shall give, if applicable, similar prior notifications to all competent supervisory authorities.

SYSTRAN has implemented technologies and put in place physical, electronic and managerial procedures to ensure the confidentiality, integrity and security of the processing of Personal Data and protect the stored Personal Data against accidental or unlawful alteration, unauthorized disclosure or access or improper use. SYSTRAN's employees, processors or any other person acting under the authority of SYSTRAN as controller, who have access to Personal Data, are obliged to respect your privacy and the confidentiality of your Personal Data.

SYSTRAN will not sell, make available to, or share Personal Data relating to you with, third parties without your consent, unless (i) required to do so by law or by judicial order or (ii) if SYSTRAN in good faith believes that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend SYSTRAN's rights and property; (3) protect against misuse or unauthorized use of the Services; or (4) protect the personal safety or property of SYSTRAN's users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

6. Your rights in relation to your Personal Data

You have the following rights in relation to the processing of your Personal Data:

• a right of access to your Personal Data, without constraint at reasonable intervals and without excessive delay or expense, which includes:
  • the right to obtain from SYSTRAN confirmation as to whether or not your Personal Data are being processed and communication of the Personal Data undergoing processing; and
  • the right to obtain rectification, erasure or blocking of Personal Data the processing of which is forbidden by any applicable law in particular because of the incomplete or inaccurate nature of the data.
• a right to modify your Personal Data information including your marketing preferences, at any time. You can opt out of receiving future marketing communications or you can unsubscribe by following instructions contained in the messages you receive.
• a right to object, on legitimate grounds, and to withdraw your consent, to the processing of your Personal Data. You also have the right to object, on request and free of charge, to the processing of Personal Data that SYSTRAN anticipates being processed for the purposes of direct marketing. You shall be informed before your Personal Data are disclosed to third parties for the purposes of direct marketing, and you are expressly offered the right to object to such disclosures. Such rights can be exercised free of charge by sending a registered letter to SYSTRAN at its registered office as indicated in clause 1 of the General Terms.

7. Contact SYSTRAN

We welcome questions and comments regarding this Privacy Policy, so feel free to contact us at privacy@systransoft.com. Because technologies on the Internet change so quickly, SYSTRAN reserves the right to update or modify its Privacy Policy from time to time. More legal information can be found in SYSTRANet Terms of Service.