Privacy Policy

Babel Street® was founded on the importance of understanding data, and we value the trust our customers, our partners and our website visitors place in us. The responsible use and protection of personal and confidential information under our care is a core value of Babel Street, Inc. (“Babel Street”). Therefore, we want you to be familiar with how we handle information relating to you as an individual, known as personal information.

This Policy describes the practices of Babel Street and its subsidiaries (including, but not limited to, Babel Street Rosette, Ltd., Vertical Knowledge L.L.C., “VK”) (collectively “we,” “our” or “us”) for the information we collect, use and disclose, By signing up and/or checking any box indicating “I agree” to the Terms of Use and/or Privacy Policy and/or using the Service(s) or using any features of the website, You (“you” or “your”) signify that you have read, understood, and accept the terms of this Privacy Policy. This document describes our policies in effect from the date last updated, as set forth above.

We gather information through the ways listed below:

• our websites located at www.babelstreet.com and developer.rosette.com
• the products and services available through our analytics, insights, and managed attribution platforms (our “Products” or “Services”) described at www.babelstreet.com/ecosystem, which includes our mobile application(s)
• our LinkedIn page located at www.linkedin.com/company/babel-street
• our social media accounts, which include @Babel4business and @Babelknowledge
• our corporate events, such as technology conferences, networking events, tradeshows or trainings

About Our Products

The mission of our company is to help our customers retrieve and make sense of large volumes of relevant publicly and commercially available information without the limits of language or origin. Our customers direct their informational queries using the Babel Street Software as a Service (SaaS) Products and decide what information they are interested in and which data sources they would like to search.

This Privacy Policy applies to the operations of Babel Street across its legal entities and subsidiaries. While certain corporate functions, such as human resources (HR), marketing, and IT are handled consistently across all entities, some variations exist based on the nature of products offered by each entity.

For HR, marketing, and IT services, Babel Street acts as a data controller across its entities. Data collected in relation to employees, contractors, and marketing leads may be processed by any of the organization’s entities but remains subject to respective national regulations.

The processing of personal data related to our Products varies by Product. Babel Street operates as a service provider to our customers, because Babel Street’s customers determine which of our products are best suited to their specific needs and goals, and we provide such products at our customers’ direction based on their business purpose.

This Policy does not apply or extend to our customers’ uses of our Products. Your use of our products and services is governed first by the terms outlined in your main Product agreement (the "Principal Agreement"). This Privacy Policy describes how we handle data across our business. Our Data Processing Agreement (DPA) outlines the specific relevant processing activities related to Products or Services.

Types of Information We Collect

Babel Street collects information about visitors to our website and/or corporate events, from potential and current customers, suppliers, or partners in connection with our Products or Services, or when you otherwise interact with us This can include:

1. Information voluntarily provided to us by website visitors, customers, suppliers, partners, event participants and other individuals, such as:

• contact details, including name, role or job title, billing or mailing address, company name, email and telephone number
• account information, if applicable
• customer service communications, including information reported to us about the operation of the Product(s) or Service(s), including bug reports or requests for enhancements
• comments on our social media posts
• financial and transaction data, including purchase history, payment and billing information
• information given to us by customers and other individuals, such as referrals or other contacts

2. Information required to operate our business or information provided during use of our Products, such as: 

• registration information necessary to set up and secure customer accounts, including a username and password, email address, and billing information (Babel Street customers may designate any username or password they choose during the process of onboarding to the Babel Street platform; therefore, no personal information is required to be included in the username or password)
• other information relating to your interactions with Babel Street, including requests for customer or sales support, feedback, and payment for the purchase of our Products
• information provided when you visit our website or any of our offices, or attend a Babel Street technology event
• any information that is submitted, stored or collected by or from users of our Products and Services

3. Usage, analytics and navigational information, such as: 

• clickstream information, such as which search engines our website visitors use most frequently
• uses of our software and the frequency of customer interactions with content within our platform
• IP address, which is only collected from customers upon logging in to the Babel Street platform
• log information, such as automatically recorded basic information that our Products send (These server logs may include information such as your IP address, the date and time of your request and an authentication token used to validate the identity of you and your computer)
• general information logged through use of our mobile application after an error occurs, such as operating system type and version, device brand and device year

When you become a Babel Street customer, your use of the Product(s) is subject to Babel Street’s subscription terms and conditions. All personal information that you provide to us must be true, complete, and accurate. If you do not want to share the necessary information to process a business transaction with us or if you do not accept the applicable terms, you will not be able to access our Product(s).

How We Use Information

Our primary purpose in collecting your personal information is to provide an efficient user experience. If you are using the Product(s) or Service(s), you are responsible for your users’ content. We use your personal information for our legitimate business purposes including:

1. Providing our Products: 

• sending details and arranging access to our Products and Services
• creating and administering accounts
• fulfilling and recording orders, transactions, payments, returns, and exchanges
• resolve disputes, collect fees, and troubleshoot problems
• update or enforce the terms of our Agreement
• customize, measure, and improve the Products and Services

We engage in these activities to manage our contractual relationship with you, with your consent, where we have a legal obligation or authorization (such as a public interest) to do so, and/or where we have a legitimate interest.

2. Product improvement: 

• to request feedback
• to provide customer surveys, contests, or promotional campaigns
• to better understand our customers and their interactions and uses so that we can improve and enhance our offerings
• to maintain, develop, improve, and market our Products and Services

We engage in these activities where we have a legitimate interest to do so. You can opt out of our marketing emails at any time.

3. Product and customer support: 

• to resolve customer issues or answer customer questions (which may include account verification)
• to inform and communicate with customers about improvements, outages, service, or updates to our Products and Services, features and terms, or promotional offers
• to provide general customer support and respond to inquiries or potential issues

We engage in these activities to manage our contractual relationship with you or where we have a legitimate interest to do so.

4. Managing our business: 

• for accounting, bookkeeping and audits, to verify that our internal processes function as intended and are compliant with legal, tax, regulatory or contractual requirements
• for website administration, analytics and the security of our Products and Services
• to improve the safety and reliability of our Products and Services
• for fraud and security monitoring purposes, and to address technical issues, for example, to detect and prevent cyberattacks
• to prepare or execute a business transaction, such as an investment, reorganization, financing, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) (“Business Transaction”)
• to comply with our legal obligations, respond to legal requests from public or government authorities, and exercise, establish, or defend our legal rights

We engage in these activities where we have a legal obligation or authorization and/or legitimate interest to do so. We may also collect and use metadata related to your use of the Product(s) and Service(s), such as anonymized content and account metrics based on or generated by your use. Metadata will be used to generate anonymized and aggregated reports for analysis purposes that do not contain personally identifiable information.

5. To deliver marketing content and enable social sharing: 

• to deliver marketing communications and content with information about our Products and our company
• to facilitate a social sharing functionality that you may choose to use

If you are not a current customer, but you have reached out to us in the past, or we have received your personal information through a technology event or other avenue, we may use your information to inform you about our Products or future events we will be hosting or attending.

If you do not wish to receive such material, or have specific contact preferences, please contact us at info@babelstreet.com. Please note that if you are a current customer and opt-out of receiving marketing-related messages from us, we may still send you important administrative messages related to your account, from which you cannot opt-out.

We engage in these activities with your consent or where we have a legitimate interest to do.

6. Participation in our events: 

We use your information when you choose to attend our corporate events, such as technology conferences, networking events, tradeshows or trainings.

We engage in these activities to manage our contractual relationship with you or where we have a legitimate interest. 

7. Aggregating and/or anonymizing: 

We may aggregate and/or anonymize information so that it will no longer relate to an identified or identifiable individual. We do so to generate other data for our use, which we may use for any business purpose.

We engage in these activities where we have a legitimate interest.

Notwithstanding anything to the contrary in this Privacy Policy or the Principal Agreement, we may access, use, preserve or disclose any information we have access to if we have a good faith belief that such access, use, preservation or disclosure is reasonably necessary to (a) satisfy an applicable law, regulation, legal process or enforceable governmental request, (b) enforce the terms of our Agreement, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of us, our users or the public as required or permitted by law.

When We Disclose Information

We disclose information in the following situations:

• To our affiliates and other third-party service providers, pursuant to a contract for services they provide to us: These include providers of services such as data hosting, payment processing, information technology and related infrastructure provision, email delivery, auditing, and other services.
• To a dedicated organization Administrator: If you are a customer of Babel Street and your organization has dedicated an Administrator of the Babel Street account, that individual may have access to some of your information, such as your username and the details of your use of our Products.
• To comply with applicable laws and regulations or to cooperate with government authorities, including law enforcement: To respond to a legal or administrative request or order, or to provide information we believe is important. This can include government authorities outside your country of residence.
• For other legal reasons: To enforce our terms and conditions or to protect our rights, privacy, safety or property, and/or that of our affiliates, employees, customers or others.
• In connection with a Business Transaction: We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of a Business Transaction. Such third parties may include, for example, investors in Babel Street or an acquiring organization and its advisors.

Except as provided above, we do not sell, rent, trade or otherwise transfer your personal information to any third-party without permission.

Information Which May Be Collected by Customers

Babel Street Products make a variety of publicly and commercially available data sources and search tools available to customers, who then decide which sources to search. Babel Street’s customers actively design, select and initiate searches of publicly and commercially available information based on the purposes relevant to their organizations’ goals and missions, and subject to any legal requirements applicable to them. Babel Street is not a bulk data provider. It acts at the customer’s direction, and the customer determines whether and how to process, retain, and delete any data (which may or may not include personal information) that it retrieves through its searches.

Therefore, distinct from any information that is collected by Babel Street for its own business purposes, customers can retrieve other information through their use of Babel Street Products, such as:

• information from publicly and commercially available data sources, including: news outlets, blogs, message boards, consumer sites, social media platforms, and traditional web or deep and dark web searches
• Other information which customers may choose to search for using our Products, including identification and background information, interactions through online platforms, interests, professional and personal data, posts and user sentiment

Any data collected by customers will be dependent on the nature of information available online at the time of the search, along with the data sources selected by the customer and the design of the customer’s search.

If a Babel Street customer searches for personal information in connection with his or her organization’s use of the Babel Street Products, the customer contractually represents to Babel Street that his or her organization has the authority to conduct such searches and retrieve any associated data.

Security

No method of transferring data over the internet or system of data storage can be guaranteed to be 100% secure. However, Babel Street follows industry standard security protocols and employs a variety of appropriate technical and organizational security measures designed to ensure the security of our Products. Specifically, Babel Street maintains compliance with NIST 800-171 and ISO 27001, a leading set of standards for information security in the SaaS realm. We also rely on the data protection measures and certifications of our third-party service providers.

You are responsible for maintaining the security and confidentiality of your account passwords and your API Key(s). You should not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email. If you believe that unauthorized access has occurred, please report it immediately to privacy@babelstreet.com.

Your Rights

If you would like to request to review, access, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information or withdraw consent, or if you would like to request to receive an electronic copy of your personal information, you may contact us by sending an email to privacy@babelstreet.com. We will respond to your request consistent with applicable law, which may vary by USA state. However, you will not be discriminated against if you exercise your privacy rights.

In your request, please make clear what personal information your request relates to. For your protection, we may only implement requests with respect to the personal information associated with information we already have, and we may need to verify your identity before executing your request. If you choose to designate an authorized agent to submit your request, we may require proof that they have been validly authorized to act on your behalf. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions initiated prior to the request.

You can also review and modify most of your personal information at any time by accessing your account. Depending on your country of citizenship, you may lodge a complaint with an applicable data protection authority for the country or region or where an alleged infringement of applicable data protection law occurs.

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided below.

Storage & Retention

When you use our SaaS Products, your content is processed through virtual machines hosted via Amazon Web Services (“AWS”). In particular, our AWS hosted virtual machines normally process the content submitted by an authorized user and return results the user that submitted the content. We reserve the right to pre-screen, review, flag, filter, modify, refuse or remove any or all user-submitted content.

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we are providing our Services to a customer, or as the customer instructs (for example, to maintain records of invoicing)
• Whether there is a legal or tax obligation to which we are subject (for example, certain laws require us to keep records of transactions for specific time periods before we can delete them)
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

When we have no ongoing legitimate business need to process personal information, we take steps to either delete or anonymize such information, or, if this is not possible (for example, the information has been stored in backup archives), then we will securely store the personal information and isolate it from any further processing until deletion occurs.

Cookies

We and our third-party service providers use cookies to administer our website. Cookies are small files that a web server transfers to an individual's computer for functionality and recordkeeping purposes while visiting that site. We use cookies to improve your user experience and the overall quality of our site, and to facilitate your ongoing access to and use of our site, among other things. Cookies may also convey information to us about how frequently you access our website and our Products and allow us to evaluate usage over time. You can view and manage cookies in your browser, including blocking and deleting cookies, though browsers for mobile devices might not offer this visibility.

Babel Street has a legitimate interest in understanding how customers and potential customers use our website. This information assists us with providing more relevant products and features, communicating value to our customers and providing appropriate staffing and resources to meet our customers’ needs.

We use several types of cookies on our website:

• Targeting - These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Strictly Necessary - These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work.
• Performance - These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
• Functional - These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of the services may not function properly.

Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has yet been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Links to Other Websites

This website and Babel Street’s Products may contain links, references or make calls to third-party websites. Please be aware that we are not responsible for the privacy practices of other websites and this Policy does not apply to any other sites. We encourage you to refer to the privacy policy of any website you visit if you have questions. The inclusion or access to third-party sites does not imply an endorsement thereof by us or of the provider of such content or service, or of any third-party website. We reserve the right to terminate any link or linking program at any time.

Sensitive Information

We ask that you not send us, and you do not disclose, any sensitive information (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation or gender identity, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) through communications with us or use of our Products.

Cross-border Transfers

Your personal information may be stored and processed in locations where we have facilities or in which we engage service providers, and, by using and interacting with the Babel Street Products, you understand that your personal information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Some countries are recognized by the European Commission as providing an adequate level of data protection. For transfers to countries not considered adequate by the European Commission, we design our Products and terms so that adequate measures are in place to protect your personal information. We utilize the standard contractual clauses published by the European Commission to ensure there is a legal basis to transfer personal data from to the United States and other countries. We have also adopted contract language for the United Kingdom.

Children’s Privacy

Due to the nature of our business, Babel Street’s website(s), Products, and Services are not intended for persons under the age of 18. We do not knowingly collect or solicit information from, market to or provide services to persons under 18 years old. By using our website(s), Products, or Services, you represent that you are at least 18.

If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information and terminate the person’s account. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact our Data Privacy Office.

Changes to this Policy

We encourage you to review this Privacy Policy to be informed of how we are protecting your information. We reserve the right to change, modify, update or amend this Policy at any time. The “Last Updated” date at the top of this Policy indicates when the Policy was last revised, and the updated version will be effective as soon as it is accessible. You agree that continued use of the website and Services shall constitute your acceptance of this Privacy Policy.

Contact Us

If you have any questions about this Policy or the privacy practices of Babel Street, please contact us at privacy@babelstreet.com:

Data Privacy Office 
Babel Street, Inc. 
1900 Reston Metro Plaza, Suite 950
Reston, VA 20190 
+1 (703) 956-3572