Effective Date: August 17, 2025

ChuukLink Interpretations and Translations (“we,” “us,” “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect Personal Information when you visit chuuklink.com (the “Site”), contact us, or use our remote interpreting and translation services (“Services”).

This Policy is designed to address U.S. federal and state laws (including California’s CCPA/CPRA, Colorado CPA, Virginia VCDPA, Connecticut CTDPA, and Utah UCPA), and, where applicable, the EU/UK GDPR. It also explains how we handle Protected Health Information (“PHI”) under HIPAA when we act as a Business Associate to a Covered Entity, and how we handle student education records under FERPA when we act as a “school official.”

1. Scope & Roles

This Policy applies to Personal Information processed by us in connection with our Services and Site.

• HIPAA: When our work involves PHI for a Covered Entity or their Business Associate, we act as a HIPAA Business Associate under a Business Associate Agreement (“BAA”). For general website visits and the Site’s contact form, we are typically not collecting PHI and the Site is not designed for PHI. Do not submit PHI through non-secure channels or our general contact forms.

• FERPA: When we provide services to educational institutions, we may act as a “school official” with a legitimate educational interest under a written agreement. We process student education records only as directed by the educational institution.

• Controller/Processor (GDPR): For the Site and our own business operations, we generally act as an independent controller. When performing certain services on behalf of clients, we may act as a processor under their instructions.

2. Personal Information We Collect

We may collect the following categories of Personal Information (which include, where applicable, “personal data” under GDPR and “personal information” under CCPA/CPRA):

• Identifiers and contact details (name, email, phone number, mailing address)

• Professional and account information (organization, role, credentials, scheduling data, communications)

• Service and transaction data (bookings, invoices, payment-related information — note: payment card data is handled by PCI-compliant processors; we do not store full card numbers)

• PHI (HIPAA) or education records (FERPA) processed only within secure, approved channels under appropriate agreements (BAAs, FERPA agreements)

• Device/usage data (IP address, browser type, pages viewed, cookies and similar technologies)

• Geolocation approximations from IP address (city/region level), where permitted

• Job applicant data (CV/resume, references) if you apply for a role

3. Sources of Personal Information

• Directly from you (forms, phone, email, secure portals, scheduling)

• Your organization or agencies that engage us (e.g., hospitals, schools, language service providers)

• Service providers and partners (payment, analytics, video meeting platforms)

• Automatically via cookies, pixels, and similar technologies on the Site

4. Purposes of Processing

• Provide, secure, and improve the Services (scheduling, interpreting, translation)

• Communicate with you (support, updates, marketing where permitted)

• Process payments and manage invoices/collections

• Comply with legal/contractual obligations (BAAs, FERPA agreements, DPAs)

• Protect against fraud, abuse, and security incidents; maintain system integrity

• Perform analytics and understand Service performance; customize and improve Site experience

5. Notice at Collection (California / CCPA-CPRA)

We collect the categories of Personal Information listed above for the purposes described.
We retain Personal Information for as long as needed for the purposes outlined, to comply with legal obligations, resolve disputes, and enforce agreements.
We do not “sell” Personal Information as defined by CCPA, and we do not “share” Personal Information for cross-context behavioral advertising.
To exercise your rights, see Section 11 below.
A “Do Not Sell or Share My Personal Information” link is available at: [Add URL on your Site].

6. Legal Bases (EU/UK GDPR, where applicable)

• Performance of a contract (providing Services to you or your organization)

• Legitimate interests (securing the Site/Services, preventing fraud, improving Services)

• Consent (for certain cookies/marketing where required)

• Legal obligations (tax, accounting, compliance)

• Vital interests / public interest (rare; e.g., preventing serious harm)

7. How We Share Personal Information

We share Personal Information in these circumstances:

• With service providers and subprocessors who perform services for us under confidentiality and, as applicable, BAAs or DPAs (hosting, backup, email, analytics, payment, video platforms)

• With clients (e.g., Covered Entities or schools) as necessary to provide the Services

• For legal reasons (to comply with law, lawful requests, or protect rights, safety, and property)

• In corporate transactions (merger, acquisition), subject to safeguards

We do not sell Personal Information and do not share Personal Information for cross-context behavioral advertising.

8. International Transfers

If we transfer Personal Information across borders, we use appropriate safeguards (Standard Contractual Clauses, Data Processing Agreements) as required by law.

9. Security

• Administrative: access control, workforce training, confidentiality obligations

• Technical: encryption in transit, secure configurations, multi-factor authentication for privileged access, audit logging and monitoring

• Physical: data center security provided by reputable hosting providers

No method of transmission or storage is 100% secure, but we implement safeguards appropriate to the sensitivity of the data.

10. Retention

We retain Personal Information only as long as necessary for the purposes described, including to meet legal, regulatory, tax, accounting, or reporting requirements, consistent with client contracts (BAAs / FERPA agreements).
We apply the “minimum necessary” principle to PHI and education records. When we no longer need the data, we delete or anonymize it per law and retention schedules.

11. Your Privacy Rights

• EEA/UK: access, rectification, erasure, restriction, portability, objection; right to withdraw consent; right to lodge a complaint

• California: right to know/access, correct, delete, limit use/disclosure of sensitive PI, and opt-out of sale/share (we do not sell/share PI)

• Colorado / Virginia / Connecticut / Utah: similar rights per state laws, including appeals of denied requests

To exercise rights, contact info@chuuklink.com. We may verify your identity and authority. Authorized agents may submit requests as permitted by law. We will not discriminate against you for exercising your rights.

12. Cookies & Tracking

We use cookies and similar technologies to operate the Site, remember preferences, and perform analytics. Where required, we request consent. You can manage cookies via browser settings and, where available, our cookie banner. We do not respond to “Do Not Track” signals at this time.

13. Children’s Privacy

The Site is not directed to children under 13. We do not knowingly collect Personal Information from children under 13 without appropriate consent. If you believe a child has provided information via the Site, contact us to request deletion.

14. Third-Party Links & Platforms

The Site may link to third-party websites or platforms (e.g., video conferencing). Their privacy practices are governed by their policies. When handling PHI or education records, we use only vetted platforms with appropriate agreements (BAA, FERPA terms).

15. Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new effective date. Material changes will be highlighted on the Site or communicated directly when appropriate.

16. Contact Us

If you have questions about this Policy or wish to exercise rights, contact:

• Email: info@chuuklink.com

• Mail: P.O. Box [Insert], Arizona, USA

• Phone: 616-990-5309

• Entity: ChuukLink Interpretations and Translations (Arizona, USA)