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Privacy Policy for Research Program

Phrase is committed to protecting the privacy of the participants in the Phrase Research Program. Participation in the Program is governed by Terms and Conditions available at https://phrase.com/research-program/terms-and-conditions/. Capitalized terms in this Privacy Policy that are not defined herein shall have the same meanings as in the Terms of Service. 

This privacy policy explains how we process personal information obtained through the Program.

  1. What Information We Collect

We collect personal information, such as full name, email, employer information, audio/video recording, or device information from Participants who voluntarily provide it to Phrase when participating in the Program. The information collected is used to understand the Participants’ opinions about the design of products developed by Phrase.

  1. How We Use Information

The personal information collected is used solely for the purposes of the research program, including contacting Participants, conducting Sessions, and analyzing the data collected from the Sessions. The information collected from the Program will be used for research purposes to improve the design of products developed by Phrase.

  1. Legal basis

We use your personal data on the following basis:

  • Service provision/fulfillment of the contractual obligations (Article 6 (1) b) GDPR).
  • The necessity to comply with our legal obligations (Article 6 (1) c) GDPR), 
  • Our legitimate interest pursuant to Article 6 (1) f) GDPR (i) to help us to (i) to improve our ability to understand your business needs; (ii) to improve and enhance our services; and (iii) to ensure network and information security.
  1. Protection of Personal Information

All personal information collected from participants is treated as confidential and is stored securely. Access to the information is restricted to the researchers involved in the Program. We will take appropriate legal, organizational, and technical measures to protect your personal data consistent with applicable privacy and data security laws.

We may share your personal data with other recipients (in particular, our suppliers as indicated below) under a written agreement that commits such recipients to appropriate safeguards in relation to handling of your personal data (including in relation to maintaining confidentiality of your personal data and implementing appropriate technical and organizational security measures).

We do not sell your personal data to any third parties.

  1. Disclosure of Information

Your personal data might be accessible to our affiliates within the Phrase Group:

  • Phrase a.s., with its registered office at Václavské náměstí 2132/47, 110 00 Prague 1, Czech Republic;
  • Phrase GmbH, with its registered office at ABC-Straße 4, 20354 Hamburg, Germany;
  • Phrase UK Ltd, with its registered office at 73 Cornhill, EC3V 3QQ, London, United Kingdom;
  • Phrase OpCo Ireland Limited, with its registered office at Unit A6, Santry Business Park, Swords Road, D09 X651 Dublin 9, Ireland;
  • Phrase OpCo Spain, S.L., with its registered office at Calle Entença, 325-335, Planta 1ª, 08029 Barcelona, Spain;
  • Phrase, Inc., with its registered office at 3710 Forbes Avenue, Second Floor, PA 15213, Pittsburgh, United States of America.

We may use the services of the following data processors to collect, store, and process personal information collected from Participants:

  • Zoom Video Communications Inc., registered office at 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA;
  • Google Inc., registered office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;
  • Notion Labs, Inc., registered office at 2300 Harrison Street San Francisco, CA 94110, USA;
  • Fellow Insights Inc., registered office at 532 Montréal Rd #275, Ottawa, ON K1K, Canada;
  • Maze Design Inc., registered office at 800 Menlo Ave, Suite 220, Menlo Park, CA 94025, USA;
  • Figma Inc., 760 Market St. Floor 10, 94102 San Francisco, USA

Our data processors are committed to protecting the privacy of personal information collected from participants. They will process personal information collected from participants in accordance with our instructions and applicable laws.

Your personal data may also be shared with other recipients, such as government authorities or other subjects where we have a valid legal title under the GDPR to share your personal data.

  1. Transfers to third-countries outside the EU

Your personal data may be transferred to countries outside the European Economic Area. These countries include: The USA, Canada, the United Kingdom and Japan.

When transferring personal data to third countries outside the European Economic Area, we will rely (i) either on adequacy decisions of the European Commission under Article 45 of the GDPR (where the European Commission recognizes that a third country ensures a level of protection adequate to the GDPR) or (ii) on standard contractual clauses agreed with the parties with which we share the data internationally.

The countries recognized by the European Commission as having an adequate level of protection can be found on the webpages of the European Commission here, and include, among others, also the USA (when sharing personal data with commercial organizations participating in the EU-US Data Privacy Framework), Japan (when sharing personal data with private sector organizations) and Canada (when sharing personal data with specific federally regulated organizations).

Where we cannot rely on an adequacy decision (in particular the EU-U.S. Data Privacy Framework, the adequacy decision on data transfer to the United Kingdom, the adequacy decision on data transfer to Canada, and the adequacy decision on data transfer to Japan), we will rely on data transfer agreements based on model standard contractual clauses approved by the European Commission to ensure that the persons to whom we transfer data in those countries commit to ensure an adequate level of protection for your personal data. You can find more information about data transfer agreements here.

  1. Retention Period

Personal information collected from participants will be deleted within 60 days after canceling their participation in the Program.

  1. Your rights

You are entitled to:

Request access to processing information

You have the legal right to request information at any time about whether we are processing your personal data. If this is the case, you have the right to be informed about the extent to which your personal data is being processed as well as to be provided with a copy of your personal data. Where the personal data is transferred to third countries, you also have the right to be informed of the appropriate safeguards implemented by us in relation to the transfers.

Request the correction and/or deletion of your personal data

You have the right to obtain the rectification of inaccurate personal data concerning you and/or to have incomplete personal data completed. In certain circumstances you have the right to erasure of the personal data concerning you without undue delay. The right to erasure does not apply, in particular, if processing is necessary to comply with legal obligations.

Object to the processing of your personal data

You have the right to object at any time to the processing of your personal data that is based on legitimate interest. We will no longer process personal data unless we can demonstrate legitimate grounds for the processing which override the interests, rights and freedoms of you as data subject or for the establishment, exercise or defense of legal claims.

Request the restriction of the processing of your personal data

You have the right to request the restriction of the processing of your personal data where (i) you have contested its accuracy for a period enabling us to verify the accuracy of such personal data, (ii) if the processing is deemed unlawful and you will oppose the erasure of personal data and request the restriction of processing instead, (iii) we no longer need the personal data for the purposes of processing but it is required by you for the establishment, exercise or defense of legal claims or (iv) where you objected to the processing of your personal data (as above) pending verification whether our legitimate grounds override those of you.

Request receipt or transmission to another organization, in a machine-readable form, of the personal data that you have provided to us

You have the right to transmit your personal data to another company in a safe and secure way without hindrance to usability in cases where the processing is based on performance of contract and the processing is carried out by automatic means.

Complain to your local data protection authority, or to a court of law, if you consider that the processing of personal data relating to you infringes the applicable data protection laws.

You may be entitled to claim compensation for damages or distress incurred or suffered in consequence of unlawful processing of your personal data.

You are not required by law to provide your personal data to us, however, if you don’t, then we may not be able to provide you or your organization with our service. If you object to the processing of your personal data, we will respect that choice in accordance with our legal obligations. Depending on the scope of your request, this could mean that we will not be able to provide you or your organization with our service.

If you would like to exercise any of your rights, please let us know by getting in touch using the contact details below.

  1. Children’s Privacy

Our Program is not intended for Participants under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are a parent or guardian and believe that we have collected personal information from your child, please contact us at privacy@phrase.com so that we can take appropriate action.

  1. Changes to Our Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time without prior notice. Any changes made to this Privacy Policy will be reflected on this page with an updated effective date.

  1. Contact Us

If you have any questions or concerns about our Privacy Policy or how we process personal data, please contact us at privacy@phrase.com.