1. Introduction
Puterize ("Company", "We", "Us", or "Our") operates the Puterize
Translate web browser extension (the "Extension"). We are committed to
protecting your privacy and handling your data in accordance with the
General Data Protection Regulation (GDPR) (EU) 2016/679 and other
applicable data protection laws. This Privacy Policy explains how we
collect, process, and protect your personal data.
2. Data Controller
For the purposes of GDPR, the data controller is:
Puterize B.V.
Oder 20 Box A9776, 2491DC
Den Haag
The Netherlands
Email: info@puterize.com Founder and Data Protection Officer (DPO) of Company can be contacted
at support@ems.puterize.com.
3. Types of Data Collected
3.1 Personal Data
When using our Extension, we may process the following categories of
personal data:
- Account Information: Email address, username, subscription
details (for Managed Service Mode)
- Technical Data: IP address, browser type and version,
operating system, device information
- Usage Data: Information about how you use the Extension,
frequency of use, preferred settings
- Content Data: Text submitted for translation (processed
locally where possible)
In Self-Service Mode, we do not collect or store personal data.
3.2 Special Category Data
We do not intentionally collect any special categories of personal
data (as defined in Article 9 of GDPR) through the Extension.
4. Legal Basis for Processing
We process personal data under the following legal bases:
- Contractual Necessity: For providing the Extension's
functionality under our Terms of Service
- Legitimate Interests: For improving our services, security,
and preventing fraud
- Consent: Where required by law and explicitly provided
by you
- Legal Obligation: When required to comply with applicable
laws
5. Data Processing Purposes
We process personal data for the following purposes:
- To provide and maintain the Extension's functionality
- To authenticate users and manage subscriptions
- To analyze usage patterns and improve our services
- To ensure the security and integrity of our systems
- To comply with legal obligations
- To communicate with users regarding service updates or security
issues
6. Data Retention
We retain personal data only for as long as necessary to fulfill the
purposes for which it was collected, including:
- Account Data: Retained for the duration of your account
plus 6 months for legal compliance
- Usage Data: Retained for 12 months for analytics and
service improvement
- Content Data: Text submitted for translation is processed
ephemerally and not stored
- Technical Data: Retained for 30 days for security purposes
After retention periods expire, data is either anonymized or securely
deleted.
7. Data Subject Rights
Under GDPR, you have the following rights regarding your personal
data:
- Right of Access: To request copies of your personal
data
- Right to Rectification: To request correction of inaccurate
data
- Right to Erasure: To request deletion of your data under
certain conditions
- Right to Restriction: To request limitation of processing
- Right to Data Portability: To receive your data in a
structured format
- Right to Object: To object to certain processing activities
- Right to Withdraw Consent: Where processing is based
on consent
To exercise these rights, please contact us at support@ems.puterize.com.
8. Data Security
We implement appropriate technical and organizational measures to
ensure a level of security appropriate to the risk, including:
- Encryption of data in transit using TLS/SSL protocols
- Pseudonymization of stored data where appropriate
- Regular security assessments and penetration testing
- Access controls and authentication mechanisms
- Incident response procedures
9. Data Transfers
Your data may be transferred to and processed in countries outside the
European Economic Area (EEA). When such transfers occur, we ensure
appropriate safeguards are in place, including:
- EU Standard Contractual Clauses
- Adequacy decisions by the European Commission
- Other legally approved transfer mechanisms
10. Third-Party Processors
We engage the following categories of data processors:
- Cloud service providers for hosting and infrastructure
- Payment processors for subscription management
- Analytics providers for service improvement
- Customer support platforms
All processors are bound by data processing agreements that comply
with GDPR requirements.
11. Cookies and Tracking
The Extension uses minimal cookies and similar technologies solely
for:
- Authentication and session management
- Remembering user preferences
- Basic analytics for service improvement
We do not use third-party tracking cookies for advertising purposes.
12. Children's Privacy
The Extension is not intended for children under 16. We do not
knowingly collect personal data from children without verifiable
parental consent. If we become aware of such collection, we will take
steps to delete the information.
13. Policy Updates
We may update this Privacy Policy periodically. Material changes will
be communicated through the Extension or via email. Your continued use
of the Extension after such changes constitutes acceptance of the
updated policy.
14. Complaints
If you have concerns about our data practices, you may lodge a
complaint with the Dutch Data Protection Authority (Autoriteit
Persoonsgegevens) or your local supervisory authority.
Contact Information
For privacy-related inquiries or to exercise your rights:
Data Protection Officer
Oder 20 Box A9776, 2491DC
Puterize
Den Haag
The Netherlands
Email: support@ems.puterize.com By using the Extension, you acknowledge that you have read and
understood this Privacy Policy and consent to the described data
practices.