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GDPR Commitment

We’re committed to helping Crowdin customers and users understand and comply with the General Data Protection Regulation (GDPR). The GDPR is the most comprehensive EU data privacy law that went into effect on May 25, 2018.

The GDPR strengthens the rights that individuals have regarding personal data relating to them and seeks to unify data protection laws across Europe, regardless of where that data is processed.

This page provides an overview of the data-related roles and responsibilities that come into effect, once you choose Crowdin as your localization platform and will explain Crowdin’s efforts to live up to the values and requirements of the GDPR.

Crowdin as the data processor

The source files and translations that you store in Crowdin are your data and you are the data controller for any personal data that may appear thought these resources. In our Terms of Service and Privacy Policy, this data is referred to as Client Data.

Using the Crowdin platform to manage your localization files means that you have engaged Crowdin as a data processor to carry out certain processing activities on your behalf.

According to Article 28 of the GDPR, the relationship between the controller and the processor needs to be made in writing (electronic form is acceptable under subsection (9) of the same Article). This is where our Terms of Service and Privacy Policy come in. These two documents also serve as your data processing contract, setting out the instructions that you are giving to Crowdin concerning the processing of your personal data and establishing the rights and responsibilities for both parties. Crowdin will only process your Client Data based on your instructions as the data controller.

All customers have a contractual relationship with our EU entity, based in Estonia.

Data transfers

One topic that often comes up with customers is data transfers outside of the EEA.

The GDPR establishes strict requirements for moving data outside of its scope of protection.

As our customers have a legal relationship with our EU entity. If Crowdin subsequently engages sub-processors outside the EEA, it is our job to ensure that we transfer the data lawfully.

We will keep an up-to-date list of sub-processors to be fully transparent about these transfers. This list will also explain what data is involved and how we have ensured that the data is adequately protected even after it leaves the EEA. We do this by making sure that our third-party service providers have signed the EU Commission’s standard contractual clauses for data transfers with us.

Crowdin as the data controller

Additionally, Crowdin acts as the data controller for the personal data we collect about users of our web application and website.

There are a few reasons we have to process personal data:

  1. We process data that is necessary for us to perform our contract with you (GDPR Article 6(1)(b));
  2. We process data to meet our obligations under the law (GDPR Article 6(1)(c)) — this primarily involves financial data and information that we need to meet our accountability obligations under the GDPR.
  3. We process your personal data for our legitimate interests in line with GDPR Article 6(1)(f).

Our legitimate interests are the following:

  • Improving the functionality of the platform to help the users’ productivity.
  • Ensuring the safety and security of your data and Crowdin’s systems.
  • Responsible marketing of our product and its features.

What is Crowdin doing for the GDPR

As an EU company, we are obligated to make sure each and every aspect of our business complies to EU laws in general and GDPR specifically.

For all those reasons we have implemented technical and organizational measures in line with the GDPR to safeguard the personal data of our customers and users that are processed by Crowdin.

Internal processes, security and data transfers

We developed and maintain necessary procedures to ensure that data processes are mapped and auditable, which is a large part of the GDPR requirements. We also have added elements to our application development cycle to build features based on the Privacy by Design principles. Any access to the Client Data that we process on your behalf is strictly limited. Our internal procedures and logs make sure that we meet the GDPR accountability requirements in this regard.

We have established a process for onboarding third-party service providers and adopting tools that makes sure that these third-parties meet the high expectations that Crowdin and its customers have when it comes to privacy and security.

Readiness to comply with subject access requests

The ownership of personal data by Data Subjects takes the central place of the GDPR. We have all the necessary means to respond to data subject requests regarding deletion, modification, or downloading of their data. This means that our Customer Support Specialists along with the Engineers that assist them in their work are well-prepared to help you in any matters involving your personal data, in addition to providing the awesome customer support experience.

Documentation

Our Terms of Service, Privacy Policy, List of Subprocessors, Cookie Statement, and Security Page are constantly being revised to increase transparency and to make sure these documents meet the GDPR requirements. As these are the basis for our relationship with you, it is very important for us to explain our commitments and your rights in these documents comprehensively and openly. Additionally, we’re constantly mapping all our data processing activities to be able to comply with the GDPR accountability requirements.

Training

All of the above is supported by extensive training efforts within the company so that the GDPR compliant processes we’ve put in place are followed. Sessions on data privacy and security are an integral part of our onboarding process and each department receives training that is tailored to their work involving personal data.

Crowdin is firmly convinced that meeting GDPR requirements is much more than just checking off boxes in a list. For us, the GDPR is truly a lifestyle of respect to individuals’ privacy and responsibility in handling personal data.

Hopefully, this helps you to better navigate the EU’s data protection requirements. If you have any questions regarding the above, you’re welcome to reach out to us at privacy@crowdin.com and we’ll do our best to explain things further.

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