Your personal information
Changes to data protection law
The law in relation to data protection is changing on the 25 May 2018 when the General Data Protection Regulation comes into force in the United Kingdom and across Europe.
1. Who we are and how you can contact us
We are Language Connect International Ltd. Our registered office is at 2 Newham’s Row, London, SE1 3UZ.
Our data protection officer and representative for all queries in relation to this policy and your data protection rights, can contacted by email at GDPR@languageconnect.net or by calling us on +44(0)2079408100. If you need to you can write to us at 2 Newham’s Row, London, SE1 3UZ.
When we refer to our website, we mean our website at https://www.languageconnect.net/.
2. Where we collect your personal information from
We may collect personal information about you in the following ways:
Data you give to us:
- Data you give to us when you register to use our services
- When you talk to us on the phone
- When you use our website
- In emails or letters to us
- When you give us feedback
- Data you give us at networking or other business-related events
Data we collect when you use our services:
- Payment and transaction data
- Profile and usage data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies (please see our separate cookies policy) and other internet tracking software
- As customers you may provide us with content for translation and interpreting purposes. Such content may contain personal data which will always be subject to the confidentiality undertakings made with you at the time you engage us to perform services.
3. Data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity data – name, username, marital status, job title.
Contact data –correspondence address, email address or telephone numbers.
Transaction data – details about payments to and from you and other details of services you have purchased from us.
Technical data – internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Data relating to children or health related data (known as “Special Categories” of data in the GDPR – We will only collect special categories of data or children’s data from you (to the extent they are contained in any material you provide us for translation purposes), if you have voluntarily provided us with this data or for the purposes of providing our services or ancillary services.
Translation Memory: Where we perform repeat translations for you, we may create a Translation Memory (TM) for your projects, which allows us to segment your provided translation content for the purposes of identifying and leveraging repeated words and phrases. This includes the application of any glossaries tailored to you containing translation preferences; for example, product names, slogans and industry specific terminology. The purpose of the translation memory and glossary is to provide cost savings and consistency across all languages we translate for you.
We may also use freelance linguists to assist in the process of translation. They may receive, as part of the assignment, the name of the client they are working on but no personal data about that client, unless such contact information is needed to perform the assignment (including but not limited to on-site interpretation projects or onsite document review). These freelance linguists may also have access to any personal data within the source documents and reference material sent to them for translation.
However, in all cases, the freelance linguists will be subject to confidentiality undertakings in which such freelance linguists undertake to keep such information confidential and only use such information in accordance with their projects.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
4. How we use your personal information
Your privacy is protected by law.
We are only allowed to use personal information about you if we have a legal basis to do so, and we are required to tell you what that legal basis is. We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.
In some circumstances we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is.
A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.
|What we use your personal information for||What personal information we collect||Our legal grounds for processing||Our legitimate interests (if applicable)|
|To register you as a new customer||
|To process and deliver your order||
|To manage payments or collect and recover money owed to us||
||To recover any debts owed to us|
|To manage our relationship with you, including notifying you about changes to our terms or privacy notices||
||To keep our records up to date|
|To administer and protect our business and our website||
||Running our business, provision of administration and IT services, network security|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||To study how customers use our services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products / services, marketing, customer relationships and experiences||
||To define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
||To develop our services and grow our business|
5. Who we share your personal information with
We may share your personal information with any of the following organisations, for the purposes of providing the services which you have requested from us:
- HM Revenue & Customs and other regulators or authorities
- Microsoft Host email, SharePoint and OneDrive, which may include personal data (names, email addresses etc.)
You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request.
We require all organisations who we share your data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow any of our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Failing to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
7. Third party links
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.
8. Transferring your personal information outside the EEA
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA we have to tell you.
Some of our subsidiaries who work on projects with our UK team are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. In the event some countries may not provide the same level of protection for your personal data as the EEA, we will only transfer such data if necessary to process your order, complete the transaction or provide additional services.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.
10. How long do we keep your personal information
We will keep your personal information for as long as you are our customer.
After you stop being a customer, because you have stopped regularly using our services, we may keep your personal information for up to 7 years for one of the following reasons:
- To respond to any questions or complaints from you
- To maintain our records
- To comply with laws applicable to us
We may use your personal information to tell you about relevant services and any upcoming offers.
We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.
You can ask us to stop sending you marketing messages at any time – you just need to contact us, or use the opt-out links on any marketing message sent to you.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes. You can ask a third party company to stop sending you marketing messages at any time, by adjusting your marketing preferences in relation to that company or by using the opt-out links on any marketing message sent to you.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of purchasing services or any other transaction between you and us.
12. Your rights
You have certain rights which are set out in the law relating to your personal information. The most important rights are set out below.
Getting a copy of the information we hold
You can ask us for a copy of the personal information which we hold about you, by email on GDPR@languageconnect.net or by phone on +44(0)2079408100. This is known as a data subject access request.
You will not have to pay a fee to access your personal data, unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances we can charge a reasonable fee or refuse to comply with your request.
We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month and in that case we will notify you and keep you updated.
Telling us if information we hold is incorrect
You have the right to question any information we hold about you that you think is wrong or incomplete. Please contact us by email on GDPR@languageconnect.net or by phone on +44(0)2079408100 if you want to do this and we will take reasonable steps to check its accuracy and, if necessary, correct it.
Telling us if you want us to stop using your personal information
You have the right to:
- object to our use of your personal information (known as the right to object); or
- ask us to delete the personal information (known as the right to erasure); or
- request the restriction of processing; or
- ask us to stop using it of there is no need for us to use it (known as the right to be forgotten).
There may be legal reasons why we need to keep or use your data, which we will tell you if you exercise one of the above rights.
You can withdraw your consent to us using your personal information at any time. Please contact us by email on GDPR@languageconnect.net or by phone on +44(0)2079408100 if you want to withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services.
Request a transfer of data
You may ask us to transfer your personal information to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
13. Making a complaint
Please let us know if you are unhappy with how we have used your personal information by contacting us by email on GDPR@languageconnect.net or by phone on +44(0)2079408100.
You also have a right to complain to the Information Commissioner’s Office. You can find their contact details at www.ico.org.uk. We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.