TRANSLATIONS EXPRESS UK ONLINE LTD.
(Version 1.1, May 2018)
We are notified holders of personal data under the Data Protection Act registration number ZA050264. The Data Protection Act requires to process personal data fairly and lawfully.
This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
TRANSLATIONS EXPRESS UK ONLINE LTD is the entity responsible for processing your personal data.
1 Personal data - what we collect and what we use it for
1.1 Master data
When you give us your information during the course of the service, we will automatically generate an account for you on TRANSLATIONS EXPRESS UK ONLINE LTD (“Account”) and collect the following personal data about you (the “Master Data”):
- Your full name
- Your telephone contact details
- Your email address
- Your address
- Your company/institution
- Your occupation
This information is mandatory, which means that it will not be possible to serve you without it. You can choose to add further personal data to your profile.
1.2 Cookies, IP address, browser settings and location
1.3 For what purposes do we use your personal information?
We will use the information you provide to us to:
- Provide our services to you, including interpretation and translation in all forms.
- Providing you with the products and services you have selected, keeping you up-to-date and informed and responding to your enquiries
- Identify you as a user
- Improve our services
- Respond to your questions and provide related customer service
- Contact you and if necessary, ask you to provide documentation
- Send you our newsletters
- Engage in various internal business purposes, i.e data analysis, auditsdeveloping new products and services, improving or modifying the Website.
- Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
- Enforce our Terms & Conditions
- Protect our operations or those of any of our affiliates
- Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
- Allow us to pursue available remedies or limit any damages that we sustain
We will also use the information in other ways for which we provide specific notice at the time of collection.
1.4 On what legal basis do we process your personal data?
We need to process your personal information in order to:
- Perform our contract with you (see Article 6.1.b of the GDPR)
- Comply with our legal obligations (see Article 6.1.c of the GDPR)
- Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
- For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when we use your services, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above and in the course of the business.
You have the right to object to how we process your personal information, or ask us to restrict the processing.
If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) - see 10, below.
2 Disclosure of personal information
2.1 Disclosure of personal information
We disclose part of your information to interprets/translators as per the specific requirements to carry out our assignments.
We do not share the documentation you send to us out of the course of the business without your authorisation. We share with partners, suppliers, agents and subcontractors who help us deliver the products and services you've chosen to use;
2.2 Other disclosures
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:
- To allow third party vendors, consultants, agents, subcontractors and other service providers to perform services on our/your behalf
- To TRANSLATIONS EXPRESS UK ONLINE LTD subsidiaries and other companies within the TRANSLATIONS EXPRESS UK ONLINE LTD group of companies
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
- To cooperate with regulatory bodies and government authorities.
- To third parties in connection with enforcement of our Terms & Conditions and Guidelines
- To third parties in order for us to protect our operations or those of our affiliates
- To third parties in order for us to pursue available remedies, or limit damages that we may sustain
- To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our services
- To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
3 Data controller
3.1 Information for which we are the data controller/processor
We are the data controller of the Master Data you forward to us.
We are also the data controller and processor of the information which is disclosed to other services (see 2.2). UK’s data protection laws govern our collection of your data.
4 Data processors and transfer of personal information outside the EU
We use external companies to maintain the technical operation of the Website and our services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.
We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorize us to instruct the data processors to process data in accordance with the Policy and for the purposes of using our services.
The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.
Some of these data processors and third party services are located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.
5 Data retention
We keep the Master Data and other personal data you provide, for as long as we have a business relationship or as needed to provide you with our services. If you choose to delete your Data we will delete this information upon your request. However, there may be circumstances where we are legally entitled to retain it;
6 Security measures
We use reasonable organizational, technical and administrative measures to protect your personal information within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
We are always working to improve our security practices and we will update this information as these practices evolve over time.
7 Access and insights into the personal data we have about you
If you have an Account with Translations Express Limited, you can log in to your Account and see what information we have about you, including your reviews, and why we have that information.
If you don’t have an Account, you can email firstname.lastname@example.org and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.
8 Correction and deletion of your personal data
You have the right to get a free copy of your personal data. If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can correct it. Please forward the new information in order to update our files. You are welcome to ask us to assist with correcting your information.
If your Account is deleted (as a client), all the data associated with your Account will be deleted, including your Master Data.
9 Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted. There may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request;
- In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
- If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at email@example.com.
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
10 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Statement. You should exercise caution and look at the privacy statement applicable to the website in question.
11 Children’s information
We do not process children’s information.
12 Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: firstname.lastname@example.org.
13 Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account and terminate our services. Your continued use of our services after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
14 Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us at: email@example.com.
You can also reach us by post.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority ICO.
Our contact details are: Translations Express, 67 Hounslow Road, Feltham, TW13 6QA, London, UK.
Our insurance provider is: HISCOX: Hiscox Customer Services, Hiscox House, Sheepen Place, Colchester, Essex, CO3 3XL