Privacy Policy for Lingsom Platform & Mobile Application

1. Service Provider and Data Protection Contact

Lingsom Oy acts as the technical service provider and Data Processor for the Lingsom ERP system and mobile application on behalf of its client organizations (interpreting agencies / Data Controllers).

Service Provider:

Lingsom Oy (Business ID: FI31278141)

Askistontie 14 A, FI-01680 Vantaa, Finland

Data Protection Contact:

Cyrus Jebraeil (lingsom@lingsom.com)

2. Purpose and Legal Basis for Processing Personal Data

Personal data is processed to ensure the technical functionality, security, provision, and maintenance of the Lingsom ERP system and mobile application. Information related to interpreting and translation orders is processed within the system on behalf of our client organizations (Data Controllers) for service execution and reporting purposes.

Legal Bases (EU GDPR):

• Performance of a contract between the Service Provider and the client organization (Art. 6(1)(b))
• Legitimate interest of the Data Controller and the Service Provider to maintain the system, client relationship, and service (Art. 6(1)(f))

3. Categories of Personal Data and Data Sources

User and Order Information:

• Basic Information: Name, email address, phone number, organization, role (client/interpreter), and order/reporting details.
• Order Details: Assignment-specific information entered by the user and communications conducted through the system.

Technical Data and Mobile App Permissions:

• Real-time Interpreting (Camera & Microphone): Audio and video stream for real-time video and phone interpreting. Audio or video from interpreting sessions is NOT recorded or stored in the system.
• Push Notifications: Device-specific identifier (device token) for delivering notifications and incoming calls (Firebase Cloud Messaging on Android and APNs on iOS).
• Crash Reports & Maintenance: Device model, operating system version, app version, and technical crash logs (Google Firebase Crashlytics).
• Usage Statistics: Basic usage statistics related to application launches (Google Analytics) using an installation-specific random identifier. Advertising IDs are not collected.
• Location Data: The application does NOT collect, track, or store user (interpreter or client) GPS location data in any form.

4. Data Storage, Security, and Transfers

• Storage Location: All data is stored and processed on secure servers within the EU/EEA.
• Data Security: Data transmission is always encrypted via secure connection (TLS/HTTPS). Access to data is restricted to authorized personnel only.
• Retention Period: Data is retained for the duration of the agreement with the Data Controller (interpreting service provider) and in accordance with the Data Controller’s instructions and legal obligations.

5. Rights of the Data Subject

Under the GDPR, users have the right to inspect their personal data, request rectification of inaccurate data, or request the deletion of their data.

As Lingsom Oy processes data on behalf of its client organizations, data requests and account deletion requests fall under the responsibility of the respective Data Controller (interpreting service provider). Account deletion requests can be initiated directly through the mobile application (Settings / Secure Messages), from where they are automatically routed to the correct Data Controller.