Transleqo Data Processing Addendum
Effective Date: October 24, 2026
1. What This Addendum Is
This Data Processing Addendum ("Addendum") forms part of the Transleqo Terms of Service between Huri Translations ("we", "us" or "our") and the business that uses Transleqo ("you" or "the client"). It applies whenever we process personal data in your content on your behalf. It needs no signature. If you want a signed copy, write to us and we will countersign it.
Words such as personal data, processing, controller, processor and data subject have the meaning they have in the EU General Data Protection Regulation (GDPR) and in French Law No 78-17 of 6 January 1978.
2. Roles
(a) Your content: For the personal data in the texts, recordings and other material you send us, and in the results we deliver, you are the controller and we are your processor.
(b) Our own records: For account, billing, sign-in, support and marketing data, we are the controller, as our Privacy Policy explains.
(c) Corrections: Under the standard option, we use corrections, with the short passages they correct, to improve our service for the language concerned. For that use only, we are a controller, and our Privacy Policy applies. Under the Never reuse option, we make no such use.
3. Details of the Processing
(a) Subject and purpose: Text to speech, transcription, live captions, translation and human review, as you order them through Transleqo.
(b) Duration: For the life of your account, then 30 days so that we can give your content back to you, then deletion. Deleted data may remain in our encrypted backups for up to 90 days.
(c) Kinds of data: Whatever personal data your texts and recordings contain, such as names, voices, words spoken and any other details they mention.
(d) Data subjects: The people who appear in or speak in your content.
(e) Special categories: We do not ask for special categories of data. If your content contains them, you are responsible for having a lawful basis to send them to us.
4. Our Duties as Your Processor
(a) Instructions: We process your personal data only to provide Transleqo under the Terms, on your documented instructions. Your use of Transleqo, your settings and your orders are your instructions. If we think an instruction breaks the law, we will tell you.
(b) Confidentiality: Everyone we allow to process your personal data is bound by confidentiality.
(c) Security: We apply the measures in Annex 2 and keep them at least at that level.
(d) Other processors: We use the providers listed in Annex 3. You authorise them. We will tell you at least 30 days before we add or replace a provider, by email and on this page. If you object on reasonable grounds and we cannot meet your concern, you may close your account before the change applies. Fees already paid are not refunded. We bind each provider to data protection duties no weaker than these, and we remain responsible to you for their work.
(e) Help with requests: We help you answer requests from data subjects, as far as the nature of the processing allows. If a data subject writes to us directly about your content, we refer them to you.
(f) Help with your duties: We give you the information you reasonably need for your security, impact assessments and consultations with supervisory authorities about Transleqo.
(g) Personal data breaches: We tell you without undue delay, and within 48 hours of becoming aware of a breach that affects your personal data. We tell you what we know, what we are doing about it and who to contact, and we update you as we learn more.
(h) End of the service: When your account closes, we keep your content for 30 days so that you can take it back, then delete it, unless the law requires us to keep it. Deleted data leaves our encrypted backups within 90 days.
(i) Records and audits: We keep a record of our processing. Once a year, or after a breach, you may ask us to answer a reasonable written questionnaire about our measures, and we will answer within 30 days. An inspection on our premises takes place only where a supervisory authority requires it, with 30 days' notice, during working hours, at your cost and without access to other clients' data.
5. Transfers Outside the European Union
(a) Where data goes: We are based in French Polynesia. Your content is stored in the United States, our encrypted backups and our mail are in Australia, and our staff work from French Polynesia.
(b) Standard Contractual Clauses: Where you are subject to the GDPR and your personal data comes to us from the European Economic Area, the EU Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021 apply between you and us and are incorporated into this Addendum by reference. You are the data exporter and we are the data importer. Module Two (controller to processor) applies. Annex 1 gives the details the Clauses ask for and Annex 2 the security measures.
(c) Our choices in the Clauses: Clause 7 (the docking clause) applies. Under Clause 9, option 2 (general written authorisation) applies, with 30 days' notice of changes. The option in Clause 11 does not apply. Under Clause 13, the supervisory authority is that of the Member State where you are established, or, if you are not established in the EU, that of the Member State where the data subjects concerned are. Under Clause 17, the Clauses are governed by French law. Under Clause 18, disputes about the Clauses go to the courts of France.
(d) Onward transfers: We pass personal data only to the providers in Annex 3, under terms that protect it as these Clauses require.
(e) Other countries: Where the law of your country requires its own transfer terms, such as the United Kingdom's addendum to the Clauses or Switzerland's adaptations, this Addendum applies with the changes that law requires, as far as the law allows.
6. Order of Precedence and Liability
If this Addendum and the Terms differ on personal data, this Addendum prevails. If the Standard Contractual Clauses apply and differ from this Addendum, the Clauses prevail. Except where the Clauses do not allow it, the limits of liability in section 14 of the Terms apply to this Addendum.
7. Changes
We may update this Addendum, for example when the law or our providers change, under section 18 of the Terms. A change never lowers the protection of your personal data without your agreement.
Annex 1. Details for the Standard Contractual Clauses
(a) Data exporter: The client, as named in its Transleqo account, acting as controller. Its contact details are those in its account. Activity: using Transleqo for text to speech, transcription, captions, translation or human review.
(b) Data importer: Huri Translations, a sole trader registered in French Polynesia under N° TAHITI 876649, PO Box 365, Maharepa, Moʻorea 98728, French Polynesia, info@huri-translations.pf, acting as processor. Activity: providing Transleqo.
(c) Data subjects, data, purpose and duration: As in section 3 of this Addendum.
(d) Frequency: Continuous, for as long as the client uses Transleqo.
(e) Sensitive data: None asked for. See section 3(e).
(f) Onward processors: Those in Annex 3, for the same purposes and durations.
Annex 2. Security Measures
(a) Transport: Every connection to and from our servers is encrypted (HTTPS). The domain's certificates may be issued only by the authorities we name.
(b) Separation of clients: Each organization's records are kept apart in the database by row-level rules, and each organization's files in its own place. We test this separation regularly with two test organizations.
(c) Access: Staff sign in with a password and a second step from an authenticator app. Only staff who need it can open client content, and our administrative actions are written to a log protected against alteration.
(d) Backups: Daily, encrypted before they leave the server, kept for 90 days, with restores tested.
(e) Uploads: Files are checked by their content before any processing, and processing runs in restricted containers with limits on time, memory and size.
(f) Retention: Content is deleted on the schedule of our Privacy Policy, and backups expire after 90 days.
(g) Output marking: Every audio file we deliver carries an inaudible mark showing that it was made by AI.
(h) Incidents: We follow a written incident plan, including how and when we tell clients.
(i) Payments: Card data stays with PayPal and never reaches our servers.
Annex 3. Our Providers
(a) expanse.host: Server hosting. Your content and our records are stored and processed on our server in New York, United States.
(b) Crazy Domains: Encrypted backups and our email, in Sydney, Australia.
PayPal (card payments) and Wise (bank transfers) handle billing data as independent controllers under their own terms. They do not receive your content.
Contact Us
For any question about this Addendum, please contact us:
HURI TRANSLATIONS
PO BOX 365, MAHAREPA
MOʻOREA 98728
FRENCH POLYNESIA
info@huri-translations.pf
+689 89 205 483