EDUBAND LLP (https://translate-your.com/ Translate Your) is committed to providing quality language services. At Your Translation, we are fully committed to processing personal data fairly and lawfully while safeguarding the privacy and confidentiality of information related to our clients and suppliers. Due to the nature of our work, we are splitting this privacy notice into two sections. Section 1 is about your personal data (contact details, etc.) which you provide to us in the course of setting up contractual relationships. Section 2 concerns personal data that may be present in the documents you provide to us for translation.
Section 1: Your personal data
Translate Your acts as a data controller, and as such has contractual reasons for obtaining and keeping personal data you provide to us. We only collect basic personal data about you, which do not include any special types of information or location-based information. These do, however, include name, email address, address, and one or two phone numbers (landline and/or mobile).
How do we collect your data?
Translate Your only collects your data directly from you. We do not engage third parties to provide us with your personal data.
Why do we need your data?
We need to know the basic personal data in order to provide you with on-going organisational updates and information in line with our overall contract with you. We will not collect any personal data from you that we do not need.
What do we do with your data?
All the personal data we process is processed by our staff in the UK, however for the purposes of IT hosting and maintenance this information is located on servers within the European Union. No third parties have access to your personal data unless the law allows them to do so.
How long do we keep your data?
We are required under UK tax law to keep your basic personal data (name, address, contact details) for six years, after this period of time the data will be destroyed.
What are your rights?
If at any point you believe the information we process about you is incorrect, you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. Please see the Subject Access Request Policy for more information.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can raise a complaint to the Information Commissioner’s Office https://ico.org.uk/.
Section 2: Personal data contained within documents for translation
It is your obligation to ensure that you have consent from the data subject or otherwise lawful grounds for sending us content containing personal data for translation. This is especially true for content containing special categories of personal data.
Translate Your acts as both a data processor and a joint controller of personal data present in documents for translation. This is because in order to fulfil our contracts with you, we need to engage sub-processors, and therefore have responsibility over how your data reaches them.
What do we do with personal data in content for translation?
We do not extract personal data in translation content for processing outside the context of the translated documents. For the purposes of IT hosting and maintenance the files are stored on servers within the European Union.
Entire documents for translation are shared using secure means with approved and compliant third-party language service suppliers as part of pre-contractual enquiries and then as part of the contract fulfilment.
Third Country Data Transfers
For the fulfilment of some contracts, we may need to transfer the data to language service suppliers outside of the EU and EU’s list of Adequate Countries. This is because most Chinese translators, for example, are based in China. If we need to send a document outside the EU/EEA in order to fulfil your contract (in accordance with article 49b of the GDPR regulations), we will inform you. It is also up to you to make sure the data subject if not you is also aware of this and gain their explicit consent.
Special Categories of Personal Data
If your documents contain special categories of personal data belonging to a third-party data subject, it is your obligation to obtain the relevant consent and establish lawful grounds for the processing of that data.
We will make all possible efforts to identify special categories of personal data within documents you provide to us prior to starting the translation workflow so appropriate measures can be taken.
We might ask you to redact identifiable information in order to minimise risk to the data subject before starting the translation workflow, especially if the contract would necessitate sending the document to language service suppliers out of the EU/EEA.
How long do we keep your data?
We are required under UK tax law to keep your basic personal data (name, address, contact details) for six years, after this period of time the data will be destroyed.
What are your rights?
If at any point you believe the information we process is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled personal data within documents for translation, you can contact us to have the matter investigated. Please see our Subject Access Request Policy for more information.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can raise a complaint with the Information Commissioner’s Office https://ico.org.uk/
Subject Access Request Policy
As per the GDPR, you have the right to be informed about the information held about you and to know who has received or will receive your personal data. To access the information held by Your Translation, please submit a formal written request. We have a Subject Access Request form for your convenience, but you are not obligated to use it; providing us with the relevant details will suffice.
Under the GDPR, you are entitled to access the following information:
1. The reasons for processing your data.
2. A description of the personal data held about you.
3. Details of anyone who has received or will receive your personal data.
4. Information about the origin of your data if it was not collected directly from you.
We are committed to assisting you with your data access request promptly and in line with GDPR requirements.
Once you have submitted your Subject Access Request, along with proof of your identity, we will respond to you in writing within one month with your data or with an indication of timelines if we cannot provide your data within this timeframe. All data requests ware considered within a maximum of three months in accordance with the GDPR. There will be no charge for making a Subject Access Request unless the request is ‘manifestly unfounded or excessive’. We may charge for multiple requests and this will be handled on a case-by-case basis.
Who to Contact
Please email our Data Protection Officer (DPO) (eduband.uk@gmail.com).
If emailing please include SUBJECT ACCESS REQUEST in the subject line of your email.