Politique de Traitement des Données Personnelles

Wagner International ("Wagner," "we," "us," or "our") is the data controller responsible for your personal data collected through our website www.wagner-international.com ("Website"), our Client Portal, and in connection with the services we provide. Wagner International is a US-based company operating virtually with a global reach. For data protection inquiries, please contact: Wagner International Email: privacy@wagner-international.com General inquiries: info@wagner-international.com Website: www.wagner-international.com

We collect and process the following categories of personal data: 2.1 Account Information • Full name • Email address • Company name and job title (optional) • Website URL (optional) • Password (stored in encrypted/hashed form) • Account preferences (language, notification settings) 2.2 Order Information • Service selections and project specifications • Source language and target language selections • Source documents and files uploaded for processing • Order history and transaction records • Delivery preferences 2.3 Payment Information • Payment method selection • PayPal account information (processed by PayPal) • Transaction identifiers and receipts • Billing address (when required by payment processor) Note: Wagner does not store credit card numbers. All payment processing is handled by third-party processors (PayPal, Wise). 2.4 Communication Data • Contact form submissions (name, email, company, message) • Email correspondence • Client Portal messages and notes • Support ticket history 2.5 Technical Data • IP address • Browser type and version • Operating system • Device identifiers • Pages visited and navigation patterns • Referral source • Time and date of visits • Cookie data (see our Cookie Policy for details) 2.6 Professional Data (for freelancer/partner applications) • Resume/CV • Professional qualifications and certifications • Language skills and specializations • Work samples and portfolio • Professional references

We process your personal data on the following legal bases: 3.1 Contract Performance (Article 6(1)(b) GDPR) We process personal data necessary to perform our contractual obligations to you, including: • Creating and managing your account • Processing and fulfilling your orders • Delivering completed work • Processing payments • Providing customer support 3.2 Legitimate Interests (Article 6(1)(f) GDPR) We process personal data based on our legitimate interests, including: • Improving our services and Website • Preventing fraud and ensuring security • Internal administration and record-keeping • Quality assurance and dispute resolution • Business analytics and reporting (using aggregated data) 3.3 Consent (Article 6(1)(a) GDPR) We process personal data based on your consent for: • Marketing communications and newsletters • Non-essential cookies (analytics, marketing) • Processing of special categories of data (if applicable) You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal. 3.4 Legal Obligation (Article 6(1)(c) GDPR) We process personal data to comply with legal obligations, including: • Tax and accounting requirements • Responding to lawful requests from authorities • Record retention requirements

We use your personal data for the following specific purposes: Service Delivery: • To create and manage your account in the Client Portal • To process, manage, and deliver your orders • To communicate with you about your projects and orders • To provide quotes and estimates • To process payments and issue invoices • To provide customer support and resolve issues Website Operation: • To operate and maintain our Website • To remember your language preference • To authenticate you and maintain your session • To protect against unauthorized access and fraud Business Improvement: • To analyze usage patterns and improve our services • To develop new features and services • To conduct quality assurance reviews • To train and evaluate our team (using anonymized data) Communications: • To send order confirmations and delivery notifications • To send invoices and payment receipts • To respond to your inquiries and support requests • To send marketing communications (with your consent) Legal and Compliance: • To comply with applicable laws and regulations • To establish, exercise, or defend legal claims • To enforce our Terms of Service

We may share your personal data with the following categories of recipients: 5.1 Service Providers • Linguists and translators: Source documents and project specifications necessary for service delivery (subject to NDAs) • Translation agencies: When subcontracting work (subject to confidentiality agreements) • AI service providers: When using AI-assisted tools (data is processed in accordance with our agreements with these providers) 5.2 Payment Processors • PayPal: For payment processing and transaction management • Wise: For bank transfer payment processing Payment processors have their own privacy policies governing their handling of your data. 5.3 Technology Providers • Cloud hosting providers: For website and Client Portal hosting • Email service providers: For transactional and marketing emails • Analytics providers: For website usage analysis (see Cookie Policy) 5.4 Legal and Regulatory • Law enforcement or regulatory bodies: When required by law, court order, or subpoena • Legal advisors: In connection with legal proceedings or disputes • Auditors: For compliance and financial auditing purposes 5.5 Business Transfers • In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and your rights under the new ownership. We do not sell your personal data to third parties. We do not share your personal data with third parties for their own marketing purposes without your explicit consent.

As a US-based company with global operations, your personal data may be transferred to and processed in countries other than your country of residence, including the United States. 6.1 Safeguards — When transferring personal data internationally, we ensure appropriate safeguards are in place: • Standard Contractual Clauses (SCCs) approved by the European Commission • Data processing agreements with all recipients • Assessment of the data protection laws of the recipient country • Additional technical and organizational measures as necessary 6.2 EU/EEA to US Transfers — For transfers of personal data from the EU/EEA to the United States, we rely on Standard Contractual Clauses and implement supplementary measures as recommended by the European Data Protection Board. 6.3 Your Rights — Regardless of where your data is processed, you retain all rights described in Section 8 of this Policy.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law: • Account data: For the duration of your account plus two (2) years after account closure • Order data and project files: For three (3) years after order completion (required for quality assurance, dispute resolution, and legal compliance) • Payment records: For seven (7) years (required for tax and accounting purposes) • Communication records: For three (3) years after the last communication • Analytics data: Aggregated and anonymized within twenty-four (24) months • Marketing consent records: For the duration of consent plus three (3) years after withdrawal • Freelancer/partner application data: For two (2) years after the last application, unless an ongoing relationship is established • Website logs: For twelve (12) months When personal data is no longer needed, it is securely deleted or anonymized. We conduct regular data retention reviews to ensure compliance.

Depending on your location and applicable laws, you have the following rights regarding your personal data: 8.1 Right of Access — You have the right to request a copy of the personal data we hold about you. We will provide this information within thirty (30) days of receiving a verified request. 8.2 Right to Rectification — You have the right to request correction of inaccurate personal data. You can update most account information directly through the Client Portal. 8.3 Right to Erasure ("Right to Be Forgotten") — You have the right to request deletion of your personal data, subject to legal retention requirements. We will delete your data within thirty (30) days of a verified request, unless retention is required by law. 8.4 Right to Restriction of Processing — You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing. 8.5 Right to Data Portability — You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller. 8.6 Right to Object — You have the right to object to processing based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests. 8.7 Right to Withdraw Consent — Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing. 8.8 Right to Non-Discrimination — We will not discriminate against you for exercising your privacy rights. 8.9 California Residents (CCPA/CPRA) — California residents have additional rights under the CCPA/CPRA, including: • The right to know what personal information is collected, used, shared, or sold • The right to delete personal information • The right to opt out of the sale or sharing of personal information • The right to non-discrimination for exercising CCPA rights To exercise any of these rights, please contact us at privacy@wagner-international.com or info@wagner-international.com. We may need to verify your identity before processing your request.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction: Technical Measures: • TLS/SSL encryption for all data in transit • Encryption at rest for sensitive data • Secure password hashing (bcrypt/scrypt) • Regular security patches and updates • Firewalls and intrusion detection systems • Access controls and authentication • Regular security audits and penetration testing Organizational Measures: • Employee and contractor confidentiality agreements • Data protection training for all personnel • Access limited to authorized personnel on a need-to-know basis • Incident response procedures • Regular review of security policies and practices • Vendor security assessments Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms: 10.1 Regulatory Notification — We will notify the relevant supervisory authority within seventy-two (72) hours of becoming aware of the breach, as required by the GDPR. 10.2 Individual Notification — If the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. Notification will include: • A description of the nature of the breach • The categories and approximate number of individuals affected • The likely consequences of the breach • Measures taken or proposed to address the breach and mitigate its effects • Contact information for further inquiries 10.3 Documentation — We maintain a register of all data breaches, regardless of whether notification is required, including the facts of the breach, its effects, and the remedial action taken.

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without verified parental consent, we will take steps to delete such data promptly. If you believe we have collected personal data from a child under 16, please contact us immediately at privacy@wagner-international.com.

12.1 Our Website may use automated processes for: • Generating instant quotations based on order parameters (word count, language pair, service type) • Fraud detection and prevention • Content recommendation and personalization 12.2 These automated processes do not produce legal effects or similarly significant effects on you. Quotations generated automatically are estimates that may be adjusted upon manual review. 12.3 You have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects. If you believe such a decision has been made, please contact us for human review.

We may update this Data Processing Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Material changes will be communicated via: • A prominent notice on our Website • Email notification to registered account holders • Updated "Last Updated" date on this page We encourage you to review this Policy periodically. Your continued use of our services after changes take effect constitutes acceptance of the revised Policy.

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with: • Your local data protection authority (for EU/EEA residents) • The Information Commissioner's Office (ICO) for UK residents • The relevant state Attorney General's office for US residents We encourage you to contact us first so we can try to resolve your concern: Wagner International Email: privacy@wagner-international.com General: info@wagner-international.com Website: www.wagner-international.com US-Based · Virtual · Available 24/7