Privacy Policy

Our privacy policy explains how we process personal data. By personal data, we mean the data we collect from our users and how we use this information to provide our services.

At DigitalTolk, we prioritize your privacy and security.

Provision of Services

In order to provide our services, DigitalTolk must identify the user who places and accepts bookings. Basic personal information and payment information are stored.

Legal basis: Performance of contract.

Legal Obligations

DigitalTolk processes personal data in order to fulfill legal requirements, such as reporting salary information. Legal basis: Legal obligation.

Customized Assignments

To ensure that each interpreter is offered suitable assignments, you have the option to indicate your preferences for desired types of assignments and share your location information. This allows DigitalTolk to offer assignments near the interpreter.

Legal basis: Legitimate interest and consent.

Support

We store information such as email addresses and bookers' names to create a smoother experience the next time the same booker makes a booking, and to more effectively offer support and handle cases. This information is also used as contact information to handle invoices, provide recommendations for new ways to use our services, and to improve our services.

Legal basis: Legitimate interest and consent.

Processing of Personal Data for Job Applications

We process personal data from job applicants in order to evaluate and manage their applications for both current and future positions. The processing is carried out to ensure a fair and professional recruitment process.

Storage of Application Data

Personal data collected in connection with job applications (such as name, contact information, salary requirements, etc.) will be stored for up to three (3) years to enable consideration of this information for future positions of a similar nature. The data may be stored longer if legal requirements or other obligations require it.

Right to Request Deletion of Personal Data

You have the right to request that we delete your personal data from our systems at any time. We process your request within a maximum of 60 days, provided that we do not have legal obligations to continue processing the data, for example under labor law or accounting laws.

Legal basis: Legitimate interest and consent.

User Experience and Use of Interpreting and Web Services

We save information about the use of our services to identify any technical problems, such as unexpected closures of the app, website, or similar situations. The purpose is to ensure that sufficient information is available to maintain high quality of our services.

Legal basis: Legitimate interest and consent.

Website Analysis

Website Analytics

We use analytics tools located on our own servers (i.e., we do not share information with Google or similar) to understand how visitors interact with our websites. This includes collecting information such as:

• which pages have been visited
• how much time is spent on each page
• referral sources (e.g., from which link you came to our website)
• type of device and browser
• approximate geographic location (e.g., city/region).

Visit ID and Cookies

Our web analytics system assigns each visitor a unique ID that is stored in a cookie in your browser. This enables us to understand visit patterns across multiple visits.

Without you providing additional information to us (e.g., via a form with name and email address), we cannot identify you as an individual – your data then only resides on our servers in a pseudonymized/aggregated format.

Linking History to Our CRM via Forms (Retroactive History Linking)

When you submit a form on our websites – for example for webinar registrations, content downloads, or other marketing-related forms – we can, after you have given explicit consent, connect:your previous visit history on our website (collected via the web analytics system)withyour contact information in our CRM. We do this to:

• better understand which topics and services you are interested in
• be able to offer more relevant information, follow-up, and content
• improve our communication and our services.

This connection only occurs when you have actively given your explicit consent in connection with the form (e.g., by checking a consent box). If you do not fill in any form, or if you do not give consent, your visit history remains only in the web analytics system and is not linked to you as an identifiable person.

Legal basis for this processing: Legitimate interest and consent (for CRM + web analytics linking, explicit consent is required).

Retention Period (Data Retention) for Website Data and CRM

• Website and visit history collected is stored for up to 12 months before the data is deleted or anonymized.
• Contact information and marketing-related information in our CRM is stored as long as we have an ongoing customer or prospect relationship with you, or until you withdraw your consent or object to the processing, unless longer storage is required by law.

Opt-out from Analytics Tracking

You can choose not to be tracked via the web analytics system at any time. To do this, you can contact us at: privacy@digitaltolk.seWe will then take reasonable measures to stop linking your activity to your visit ID and/or your contact card in our CRM.

Marketing

Information is collected to market relevant services. We collect information about the services used and how they are used.

For marketing purposes, we also use our marketing CRM, where your contact information and your consents can be stored together with information about which mailings, events, and content you have accessed. When you have given explicit consent via our forms, information about your website use can be linked to your profile in our CRM so that we can adapt communication to your interests.

Legal basis: Legitimate interest and consent (for CRM + web analytics linking, explicit consent is required).

Data Collected

The exact information collected varies depending on the type of user using the service.

Contact Information

When registering a customer or interpreter in our service, basic contact information, payment information, personal identity number, and similar user information are collected.

Service Information

We store, among other things, information about handled bookings, how bookings have been placed and accepted, relevant call data for training and analysis, feedback provided, accepted assignments, as well as aggregated feedback and ratings about people's use of the services.

Interpreter and Customer Service

When contacting our interpreter and customer service, we collect information to assist the person with their case.

LanguageLearn (English version)

LanguageLearn is DigitalTolk's platform for personalized Swedish training, used by students in Komvux and SFI and by staff in elderly care. It is provided to organizations, such as municipalities, regions and care providers, and is not sold directly to individuals.

The sections above on website analytics, cookies and marketing also apply to languagelearn.digitaltolk.se. Activity inside the platform is never used for marketing.

Who is responsible for your personal data

If you are a student or staff member using LanguageLearn, the organization that gave you access (for example your municipality's adult education, or your employer in elderly care) is the data controller. That organization decides why and how your learning data is processed.

DigitalTolk processes the data on the organization's behalf as a data processor or sub-processor, depending on how the service is provided, and only according to the organization's instructions.

Purposes and legal basis

Providing the platform

We create accounts, run the diagnostic level test, build individual study plans, provide exercises and record progress. The legal basis is determined by the organization that is the data controller.

AI adaptation

We adapt the level, content and style of exercises and create new exercises when the user needs more practice. The legal basis is determined by the organization that is the data controller.

Conversation practice

The user practices realistic situations, such as a job interview, healthcare visit or workplace handover, in text or speech with digital conversation partners. The legal basis is determined by the organization that is the data controller.

Teacher follow-up

Teachers see the student's activity and progression, receive signals when a student loses momentum and collect evidence for assessment. The legal basis is determined by the organization that is the data controller.

Support and technical operations

We help users, log errors and unexpected exits to keep the service stable and secure. This is done on behalf of the organization and according to its instructions.

Service development

We improve pedagogy and the platform using anonymized or aggregated usage data. The data is not treated as identifiable personal data once it has been anonymized.

AI and voice

LanguageLearn uses generative AI to adapt exercises, generate practice material, act as a conversation partner and give feedback on answers and pronunciation. The pedagogy and content are reviewed by humans.

No training of external AI models. User data is not used to train external AI models.

AI processing takes place with EU data residency and under agreed instructions. Voice.

When you speak in an exercise, your voice is processed to transcribe it and assess pronunciation. We do not use voice recordings to identify you.

Audio recordings are deleted after 90 days. What you share in conversations.

The exercises simulate real situations. You do not need to share real information about your health, family or other private matters; we recommend using fictional details.

Automated assessments. The platform places users on a CEFR level (A1–C1), determines when a module is completed and flags users who may need support.

The assessments only guide the training. Grades and other decisions about you are made by your teacher or manager, not by the platform.

Data we process

LanguageLearn processes the following types of data:

• Account data: name, email address, organization, class or work unit, role, one-time login codes and password reset tokens.
• Profile data: language level, goals, profession or areas of interest.
• Learning data: level test results, study plan, completed exercises and modules, streaks and badges, time spent and last login.
• Conversation and voice data: written and spoken answers, transcripts and pronunciation feedback.
• Assessment data: progress against course goals or competency areas, evidence linked to knowledge requirements and flags for support needs.
• Technical data: device and browser, IP address, application and error logs, and AI usage logs.

This data comes from the organization that creates your account, from you when you complete your profile or contact support, from your use of the platform, and from teachers who assign exercises.

Who can see your data

Your teacher can see activity, progression, course goals met, flags for support needs and evidence for assessment. For exercises from the content library, the teacher can also see the audio and text of your answers, but not your practice mode.

Our staff can see only what their tasks require, for example support and operations, and are bound by confidentiality. No other roles, such as principals, managers or HR, currently have access to LanguageLearn.

We will update this policy before any such access is introduced.

Storage

LanguageLearn user data is stored in Sweden. AI processing takes place within the EU.

Digital Interpretations Scandinavia AB is ISO 27001 certified. We use technical service providers to provide, secure and operate the service.

They may process personal data only to the extent needed for the service and under agreed instructions.

Retention

Account, profile, learning and assessment data is retained as instructed by the organization. When the agreement ends, data is returned upon customer request.

Users who leave a course or job are deleted or anonymized 12 months after the account is deactivated, unless the organization instructs otherwise. Voice recordings are retained for 90 days.

Personal data breaches

If a personal data breach affects LanguageLearn user data, we notify the organization without undue delay, so that it can report the breach to the Swedish Authority for Privacy Protection (IMY) within 72 hours where required.

Your rights in LanguageLearn

For data in the platform, contact the organization that gave you access first. It responds within one month, and we help it carry out the request.

If you are unsure who to contact, write to privacy at digitaltolk.se and we will help.

How Personal Data is Collected

Collection of personal data occurs through several channels, including:

• Information the user themselves provides when registering on our platform.
• Information the user provides when contacting our interpreter and customer service via email, fax, recorded calls, and chat conversations.
• When the user utilizes our services, for example by visiting our website to place or accept bookings.
• Information collected via so-called cookies and the website analytics tool, which retrieves data from your browser.
• Information we obtain from third parties, for example the criminal records register.
• Information generated when you fill in forms on our websites (e.g., webinar registrations, material downloads, or contact forms), including your potential consents, which are stored in our CRM.

How Information is Protected

DigitalTolk uses technical tools and organizational processes to secure personal data. Communication with our services is protected through SSL certificates, and sensitive information is encrypted with one-way algorithms.

These measures guarantee correctness and unchanged data (integrity), protection against unauthorized access (confidentiality), and regulated access for authorized individuals via access controls. All staff, consultants, contractors, and subcontractors are bound by confidentiality agreements, and DigitalTolk ensures that relevant parties only have access to the information required for their work tasks.

In addition to this, DigitalTolk has developed procedures for handling:

• System development with focus on security and permissions
• Data integrity
• Information security incidents
• Training of new staff
• Secure access to physical equipment and server rooms
• Continuous risk analysis and risk management
• Secure login and device configuration

Transfer to Third Countries

As a general rule, DigitalTolk does not transfer personal data to countries outside the EU/EEA. If such transfers nevertheless occur, they take place in accordance with applicable data protection legislation.

When Basis for Continued Collection of Personal Data is Lacking

When there is no longer a valid basis for continued collection of personal data, DigitalTolk removes data that no longer has a purpose to be stored for. Personal data from contractors who have not performed assignments are deleted regularly, as well as upon the contractor's request.

Certain data required under other applicable laws, such as the Accounting Act, are retained. Authority disclosure: According to law and authority decisions, we may be asked to disclose contact, salary, and invoice information to authorities such as the Swedish Tax Agency and the Swedish Social Insurance Agency, among others.

Your Rights Under Data Protection Legislation (GDPR)

You have the right to:

• Request access to the personal data we process about you (register extract).
• Request correction of incorrect or incomplete information.
• Request deletion of your personal data ("the right to be forgotten") when there is no longer a legal basis for the processing.
• Object to certain processing, for example processing for direct marketing.
• Restrict processing in certain situations.
• Withdraw your consent at any time, when processing is based on consent (e.g., linking website history to our CRM).
• Transfer your data (data portability) in certain cases.

To exercise your rights, you can contact us at: privacy@digitaltolk.seYou also have the right to file a complaint with the Swedish Authority for Privacy Protection (IMY) if you believe that we are processing your personal data in violation of applicable legislation.

Contact

For further questions, please contact the person responsible for data protection issues at DigitalTolk via: privacy@digitaltolk.se‍