Privacy Policy

Defrilex LLC, a Florida limited liability company trading as Defrilex (“Defrilex”, “we”, “us”, “our”), provides white-label interpreting, translation and multilingual staffing to language service providers (LSPs), business process outsourcers (BPOs), and enterprises in healthcare, government, legal, financial services and retail.

This policy covers defrilex.com, our talent network, our email programmes, and the Defrilex Language Solutions Marketplace at app.defrilex-ls.com where you use it. Defrilex LLC operates more than one brand website, and each one publishes its own copy of this policy. This copy is the one that governs defrilex.com. It sits alongside our Terms of Service, which set out the rules for using the site itself.

The two roles we play

Data protection law separates two things: deciding why personal data is handled, and handling it because someone else told you to. The first role is called Controller, the second Processor. We occupy both, in different situations, and which one applies decides who you should go to when you want something done about your data.

• We are a Controller for website visitors, business prospects, mailing list subscribers and members of our talent network. We chose what to collect and why, so you exercise your rights directly against us and we answer you directly.
• We are a Processor for personal data we handle on behalf of a client — above all, information about the client’s own end customers that arises during an interpreting or support session. We act on that client’s documented instructions and nothing else. If you are one of those end customers, the client is your first point of contact, and we support them in answering you.

Five groups of people appear in this policy. Find yourself here, then read the rest with that group in mind.

• Website visitors. Anyone browsing defrilex.com.
• Business prospects and clients. Professionals who enquire about our services, request documentation, run a pilot, or manage a live client account.
• Talent. Interpreters, translators and multilingual agents who apply to join our network, or who are already members of it.
• Subscribers. People who signed up for job alerts or network updates.
• Client end customers. Individuals — patients, claimants, callers — whose conversations are interpreted by our talent. We handle this data as a Processor for the client.

Interpreted conversations

Interpreting is our core service, so it is worth being blunt about what happens to a conversation. An interpreter hears it and relays it in real time. We do not record, transcribe or store interpreted sessions unless a specific client contract expressly requires it. Where a contract does require recording, the client is the Controller for that recording and the client sets the retention period.

Our talent are contractually barred from recording sessions and from storing end-customer information on personal devices. They are required to work in a private, secure environment where the conversation cannot be overheard.

Sensitive information

We do not ask website visitors or business prospects for sensitive personal information, and you should not send it to us through a web form. Where sensitive information does reach us — health information disclosed during a healthcare interpreting session, or a background check result for a talent application — we use it only for the purpose it was provided for, and we disclose it to no one else except as set out in section 08.

We use personal information to:

• Provide, operate and improve our interpreting, translation and staffing services;
• Match talent to client programmes on language pair, credentials and availability;
• Respond to enquiries and manage client and talent relationships;
• Send job alerts and network updates to the people who asked for them;
• Process payments to talent and invoice clients;
• Vet and credential talent, including background checks where a role requires one;
• Secure our systems, prevent fraud and abuse, and investigate incidents;
• Comply with legal, tax and regulatory obligations.

Automated decision-making

Matching talent to assignments is assisted by automated ranking on objective criteria such as language pair, certification and availability. No decision that materially affects a person — acceptance into the network, engagement for an assignment, removal from one — is made by automated means alone. A person reviews the shortlist and decides. If you believe a decision about you was made automatically, ask us and a human being will review it.

If you are in the European Economic Area, the United Kingdom, Switzerland or Brazil, we rely on the following legal bases under the GDPR, the UK GDPR and the LGPD:

• Consent — mailing list subscriptions, job alerts and talent applications. You can withdraw consent at any time, and withdrawing it does not undo processing that was lawful before you withdrew.
• Performance of a contract — running your account, engaging you for assignments, paying you, and delivering the services a client has contracted for.
• Legitimate interests — answering business enquiries, securing our platform, preventing fraud and developing our business. We weigh these against your rights, and you can object at any time.
• Legal obligation — tax reporting, sanctions screening, records retention and responding to lawful requests from authorities.

Special category data, such as health information arising in a healthcare interpreting session, is processed as a Processor on the client’s documented instructions. The client is responsible for establishing the condition that permits that processing, and we act only within it.

This is a short section, and an accurate one. It lists everything this site puts in your browser, and every third party that sees a request when one of these pages loads.

Where the law requires consent for that cookie, we rely on consent. You can refuse it: block or delete cookies for this site in your browser settings, or use your browser’s private mode. Refusing changes nothing about your ability to read this site or to send us an enquiry — the form works either way, and we simply lose the attribution.

Where this site carries job listings, a single sessionStorage entry remembers which listing you came from, so an application carries the right context with it. It is deleted the moment you close the tab, it never leaves your browser, and it holds no personal data.

Fonts

The typefaces on this site are loaded from Google’s font service. That is a request to a third party, so your IP address and browser user-agent reach Google each time a page loads. The font service sets no cookie, it is not a tracker, and nothing about you comes back to us from it — but it is still a disclosure to Google that you did not choose to make, so it belongs in this section. We are moving to self-hosted font files to remove the request.

The Marketplace platform

The Marketplace at app.defrilex-ls.com uses strictly necessary cookies to keep you signed in, hold your session together and protect against cross-site request forgery. Those cookies cannot be switched off, because the platform cannot authenticate you without them. The Marketplace runs no advertising or analytics cookies.

You can block or delete cookies in your browser settings at any time. On this site that stops the HubSpot tracking described above, and nothing else changes: every page still reads normally and the enquiry form still works. It will stop you signing in to the Marketplace.

We email job alerts and network updates to people who joined our talent network or subscribed on defrilex.com. Public signups use double opt-in: you confirm your address by clicking a link in a confirmation email, and until you do, we send you nothing else.

Every marketing email carries a one-click unsubscribe link and the postal address of our head office. Unsubscribing takes effect immediately — not within the ten business days the law allows us, which is a window we have no use for.

When you unsubscribe, or when your address hard-bounces, we add it to a suppression list. We keep that list indefinitely, because deleting it is exactly how companies end up emailing people who already asked them to stop. The list holds the minimum needed to recognise your address and keep it out of every send, and it is used for nothing else. It is never a marketing list.

Operational messages are different from marketing. Assignment details, payment notifications, security alerts and notices about changes to this policy are part of the service you have with us, so unsubscribing from job alerts does not switch them off. If you want to leave the network altogether, tell us and we will close your profile.

We share personal information with the service providers that help us operate. Each one is bound by a written agreement that limits it to processing on our instructions, and none of them may use your data for their own purposes.

Our interpreter and agent network

Delivering an interpreting service necessarily means a person hears the conversation. There is no way around that, so we state it plainly: our vetted interpreters, translators and multilingual agents act as our subprocessors when they handle client and end-customer information. They are bound by written confidentiality and data protection obligations that survive the end of their engagement, they are barred from recording sessions or storing end-customer data on personal devices, and they must work in a private, secure environment.

Other disclosures

• Clients. Where you are engaged on a client programme, we pass the client the professional information it needs to credential and schedule you.
• Professional advisers. Lawyers, accountants, auditors and insurers, each under a duty of confidentiality.
• Legal and safety. Where the law, a court order or a valid request from a public authority requires it, or where disclosure is necessary to protect the rights, safety or property of any person.
• Corporate transactions. In a merger, acquisition, financing or sale of assets, personal information can transfer as part of the transaction. We will tell you, and the protections in this policy continue to apply to the data that moves.

We update this list when our providers change. Clients under a Data Processing Agreement receive advance notice of any new subprocessor and may object, on the terms set out in that agreement.

We are established in the United States and our network spans many countries, so personal information crosses borders, including into the United States.

Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we rely on the European Commission’s Standard Contractual Clauses, together with the UK International Data Transfer Addendum where the UK GDPR applies. We carry out transfer impact assessments where they are required, and we document the outcome.

Some of our United States providers are self-certified under the EU–US Data Privacy Framework and its UK and Swiss extensions. Where a provider holds a current certification, Defrilex may rely on that certification for transfers to that provider. Defrilex LLC does not itself claim Data Privacy Framework certification, and relies on Standard Contractual Clauses for transfers to itself.

You can ask for a copy of the safeguards that apply to your data. Write to us at the address in section 15 and we will send it.

Where the law obliges us to keep something longer — a tax record, or data covered by a litigation hold — we keep it for as long as that obligation lasts and delete it when the obligation ends.

Which rights you hold by law depends on where you live. We extend the core rights — access, correction and deletion — to everyone, wherever you are, because operating two standards is how mistakes happen.

• Access a copy of the personal information we hold about you;
• Correct anything that is inaccurate or incomplete;
• Delete your information, subject to the obligations that require us to keep some of it;
• Port your data to another provider in a structured, machine-readable format;
• Object to or restrict processing, including processing based on legitimate interests;
• Withdraw consent at any time, where the processing rests on consent;
• Limit the use of sensitive personal information to what is necessary to deliver the service;
• Opt out of sale or sharing. We sell nothing and share nothing for cross-context behavioural advertising, so there is nothing to opt out of — the right still stands, and we will honour any request made under it;
• Not be discriminated against for exercising any of these rights. We will not deny you service, charge you a different price, or give you a lesser standard of service because you asked.

How to exercise them

Write to privacy@defrilex.com with “Privacy request” in the subject line. You can also reach us through our contact page or at the postal address in section 15.

We acknowledge every request within ten days and respond substantively within thirty days. Where a US state statute allows forty-five days and your request is genuinely complex, we use the longer period and we tell you that we are doing so, before the thirty days are up.

We verify your identity before acting on a request, and ask only for what is necessary to do it. An authorised agent can submit a request for you with written proof of authority.

Global Privacy Control

We honour the Global Privacy Control signal. Because we neither sell nor share personal information, the signal changes nothing about how we treat you. It is respected all the same, and we would rather recognise it than argue about whether we have to.

Complaints

If you are unhappy with how we have handled your information, tell us first and we will try to put it right. You also have the right to complain to a supervisory authority, and you do not need our permission to do it:

• European Economic Area — the data protection authority where you live, where you work, or where the issue arose.
• United Kingdom — the Information Commissioner’s Office.
• Brazil — the Autoridade Nacional de Proteção de Dados.
• United States — your state Attorney General, where your state provides that route.

We apply technical and organisational measures proportionate to the risk: encryption of data in transit and at rest, role-based access control granted on a least-privilege basis, multi-factor authentication on staff and administrative accounts, and monitoring of our networks and applications. Confidentiality and security obligations are written into every contract and flow down to everyone who handles data on our behalf.

Talent must work in a private, secure environment, are barred from recording sessions, and may not store end-customer information on personal devices.

No system is perfectly secure, and any company that tells you otherwise is overselling. What we can promise is what we do when something goes wrong. If a breach affects your personal information, we notify you and the relevant regulators within the timeframes the law sets. Where we are acting as a Processor, we notify the client without undue delay so the client can meet its own obligations.

If you think you have found a vulnerability in our systems, report it to privacy@defrilex.com. We will not pursue legal action against researchers who act in good faith, avoid privacy violations and service disruption, and give us reasonable time to fix the issue before disclosing it.

Our services and our talent network are for adults aged eighteen and over. This website is not directed at children, and we do not knowingly collect personal information from anyone under eighteen. If you believe a child has given us personal information, contact us and we will delete it.

An interpreted conversation can involve a minor — a child receiving medical care, for instance. That information belongs to the client as Controller. It is handled under the client’s instructions and the Data Processing Agreement we hold with them, and the client is the right place to direct any request about it.

We update this policy when our practices change or the law does. The effective date at the top of this page always names the version you are reading.

Where a change materially affects your rights or how we use your information, we give at least thirty days’ notice before it takes effect — by email to subscribers and network members, and by prominent notice on this website. Where a change needs your consent, we ask for it rather than assume it.

This is the first published version of this policy on defrilex.com. When we replace it, previous versions will remain available on request. Changes to the rules for using the site are handled separately in our Terms of Service.

For any privacy question, or to exercise a right under section 11:

Defrilex LLC
12000 Biscayne Blvd, Suite 205
Miami, FL 33181
United States

Email privacy@defrilex.com
Telephone +1 (888) 982-0561
Online contact Defrilex

If you are a client exercising rights on behalf of your own data subjects, route the request through your account manager so we can handle it under the Data Processing Agreement we hold with you. That keeps the record straight on both sides.