1. Purpose of this declaration
Throughout this Policy we use the term “processing” to cover all activities involving your personal data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of data.
2. Who we are and what we do
Transcultural Translation Services S.R.L., hereinafter also referred to as “TTS” or “We”, is a Romanian company providing language services, registered office in Bistrita, Aleea Heniu, nr. 2, bl. 10C, sc. A, ap. 20, 420111, Bistrița-Năsăud, Romania, legally represented by Ciprian Iovu and Sabine Crihan, as directors.
3. How to contact us
4. What personal data we collect
We may collect personal data from you in the course of our business, including through your use of our website, when you contact us or request information from us, when you engage our language services, or as a result of your relationship with one or more of our staff members or customers. Both our website and our services are aimed at persons over 18 years of age, so we do not intend to collect and process data from persons under this age through our website.
Our primary purpose in collecting personal data from you is to help us:
- Verifying your identity
- providing our services
- improving, developing and marketing new Services
- dealing with requests made by you on the website or in connection with our services
- performing our contract obligations with you.
- protecting our rights, property or safety or that of third parties, including other customers and users of our website or services
- using personal data in cases required or permitted by law
In order to achieve these objectives, we may process the following personal data:
a) If you are a visitor to the website:
- Information obtained via cookie files, such as website display preferences, language selected, consent to data processing via cookies or information that cannot be used to identify you with a unique profile but is used by Google Analytics or Google Ads for advertising purposes
b) If you are a visitor to the website and you contact us using the contact form on the website:
- Full name
- Contact information (email address, phone number)
- Other information you choose to provide us with via the “Message” field in the contact form
- Information obtained through cookie files, as described in the section “Cookies Policy”
c) If you interact with us via social media:
- Full name
- Social networks and online platforms profile data (nickname, photo, biography)
- Social media post content, reviews, ratings, location data
d) If you are an individual and receive our services as a customer or are a potential customer:
- Basic information such as your name, the company you work for, your position and your relationship to a person
- Contact information such as your postal address, email address and telephone number(s)
- Financial information, such as payment information
- Identifying or historical information provided by you or collected as part of our customer acceptance policy
- Photographs, audio and/or video recordings taken in the course of or in connection with certain language service provision procedures
- Information you provide to us for the purpose of attending meetings and events, including dietary preferences, which may reveal information about your health or religious beliefs
- Any other personal information about you or other third parties that you may provide to us for the purpose of receiving our services
We use this information to facilitate the provision of our services to you, the customer. In addition, we may process identifying and historical information about you as part of our acceptance, administration and marketing processes, including checks for money laundering, disputes, reputation and financial capability, and to meet any other legal or regulatory requirements to which we may be subject. Information provided by clients may be disclosed to third parties to the extent reasonably necessary (for example, when we seek external advice or external experts).
For customers and potential customers, we also collect data that allows us to promote our products and services that may be of interest. For this purpose, we may collect:
- Your name and contact details
- Other business information such as job title and company you work for
- Areas or topics that interest you
- Additional information may be collected, such as events you attend and, if you provide it, dietary preferences, which may indicate data about your health or religious beliefs
If we ask you to provide any other personal data that has not been described above, the personal data we ask you to provide and the reasons why you are asked to provide it will be made clear to you at the time you are asked to provide that personal data.
e) If you supply goods or services to us or act as a representative, employee or any kind of agent of a company supplying goods or services to us (“Supplier”)
In the course of dealing with our suppliers, personal data such as personal data relating to any officers or staff of our corporate suppliers or potential suppliers, any vendor or buyer or personal data relating to their consultants or staff or other similar data may be transmitted to us.
The data processed in relation to these data subjects are usually name, surname, telephone number, email, position and/or relationship with the provider, any identifying data from a power of attorney granted to them by the provider, data necessary for the resolution of complaints, which, in addition to a complaint identifier, are usually limited to the type of data mentioned above. Other types of data transmitted by the supplier may also be processed as necessary.
f) If we process your data in the course of providing language services on the instructions of third parties
If you are an individual whose personal data is processed by us as a result of providing services to other individuals (including clients – individuals and corporate clients) or on the instructions of institutions or third parties, we will process a variety of different personal data depending on the services provided.
This may include personal data relating to, without limitation, any of the officers or staff of our corporate clients or potential corporate clients, including personal data relating to their language consultants or other advisers, any adversary or seller or buyer dealing with corporate or individual clients.
We may also need to process various categories of personal data in connection with other third parties instructed either by our clients or by other persons or companies involved in providing services to our client.
This is a non-exhaustive list reflecting the varied nature of personal data processed within our company.
g) Data processed by third parties
- Data processed through social media plugins. Please be aware that by accessing our website, third parties may collect data about you as a result of integrating social media plugins, such as “Like” and “Share” buttons, even if you have not clicked on them or are not a member of those social media networks. Our company is not involved in any way in the data processing operations of social networks, other than collection and transmission, which occur automatically, without us having access to or control over the data collected by social networks. For more information please refer to the privacy policies of the social networks whose plugins appear on our website (Facebook, LinkedIn etc).
- External links. Our website may contain links to third-party websites. We provide these links as a convenience and our company does not control and is not responsible for the privacy practices or the content of such websites. The responsibility for how these third parties process your personal data rests entirely with them. Please review their privacy policies and terms and conditions of use before accessing these websites to ensure that your data is processed as you expect.
5. How we use your personal data
We may use your data for the following purposes:
a) Fulfilment of services and customer services
We collect and store the personal data you submit to us during your use of our website and/or services to enable us to perform the services.
Our website uses different user interfaces to allow you to request information about our services, including electronic contact forms and a telephone information service. Contact details may be requested in each case, but other details of personal data that are relevant to your request for services you are invited to submit by email. This information is used to enable us to respond to your requests.
What is our legal basis?
It is necessary for us to process your personal data in order to fulfil our obligations under any contract we may have with you. Failure to provide this data automatically results in the impossibility of concluding and/or performing the contract.
b) Business administration and compliance
We use your personal data for the following business administration and compliance activities:
- to comply with legal obligations (including in relation to know-your-client/money laundering, professional record-keeping obligations, instructions of a court or other authority or the provisions of a court order or administrative or similar act) or similar obligations
- to exercise our legal rights;
- in connection with a business transaction, such as a merger, restructuring or sale
- in connection with participation in a public procurement procedure
What is our legal basis?
Where we use your personal data to comply with legal obligations, we do so precisely because it is our legal obligation to use your personal data for this purpose. If we use your personal data to exercise our legal rights, in connection with a business transaction or in connection with participation in a public procurement procedure, it is in our or a third party’s legitimate interest to do so.
c) Providing language services to our clients
We use your personal data for the following activities when providing language services to our clients
- linguistic and cultural consultancy
- participation in negotiations, mediations, transactions
- fiduciary activities
- drafting, certification, transmission, registration of documents, archiving, transmission of correspondence
- to protect the rights of third parties
- taking any necessary legal action in the course of providing services to our customers
What is our legal basis?
When we use personal data to provide language services to our customers or to protect the rights of third parties, we do so in the performance of a task that serves a public interest.
d) Marketing communications
We may carry out e-mail marketing or direct marketing activities using your personal data.
We may use information we observe about you from your interactions with our website, from our email communications to you and/or through the services to send you marketing communications.
Our communications are mainly intended to inform you about topics that may be of interest to you.
What is our legal basis?
It is in our legitimate interest to use personal data for marketing purposes.
e) Customer knowledge and analysis
We may analyze your contact details along with other personal information we observe in connection with your interactions with our website, email communications to you and/or our services, such as the services you have viewed.
Files of this type have fixed retention times and remain passive, contain no malware and do not access information on your hard drive. These types of files can only be accessed by the webserver that placed them.
Information contained in cookies may include the following:
- IP address to monitor traffic and volume of site usage
- the type of device or browser used
- a session ID to track usage statistics on our website
- display or navigation preferences
- information about your personal or professional interests
- general demographic data that cannot uniquely identify you
- previous experiences with our products and services, including the website (e.g. website pages you have visited)
- contact preferences
- preferences in terms of marketing communication or advertising
Cookies allow us to count users who have visited a page and to collect other types of aggregate information, such as which pages or types of content were of most interest to you.
By using this information, we can measure the effectiveness of our content and how visitors use our website and services. This allows us to find out which pages of our website are most attractive to our visitors and which parts of our website are most interesting.
We may also use this information for marketing purposes (see the marketing section above for further details).
What is our legal basis?
Where your personal data is not in an anonymised form, it is in our legitimate interest to use your personal data in order to ensure that we provide the best products and services for you and our customers.
6. What is our legal basis for processing your personal data
It is necessary for us to use your personal data:
- To perform our obligations under any contract we may have with you.
- It is in our legitimate interest or the legitimate interest of a third party to use personal data in order to ensure that we provide the Services in the best possible way
- It is our legal obligation to use your personal data to comply with the legal obligations imposed on us
- It is necessary for us to use your personal data for the performance of a task that serves a public interest
We may process special categories of data in connection with the provision of our services when:
- processing is necessary for the establishment, exercise or defence of legal claims (data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical convictions, trade-union membership, data concerning a natural person’s health, life or sexual orientation)
- you have given your explicit consent to the processing of such personal data (data on dietary preferences, which may indicate data about your health or religious beliefs, for example)
- the processing relates to personal data which are manifestly made public by you (e.g. sexual orientation, philosophical or religious beliefs)
7. With whom we share your personal data
TTS may share personal data with various categories of third parties as necessary:
- Our professional consultants, subject matter experts and accountants
- Public or regulatory authorities, tax authorities
- Third parties involved in the services we provide to clients, such as consultants, arbitrators, mediators, court clerks, notaries public, bailiffs, witnesses, court, document review or document and activity management platforms, experts such as tax consultants or valuers, etc.
- Third parties to whom we outsource certain services, such as, without limitation, consulting services of various specialties, document processing, accounting, confidential waste disposal, auditing, training, computer systems and software providers, IT support service providers, document and information storage service providers, cloud service providers, marketing agencies, PR, advertising, advertising production, event management, human resources and payroll companies, security firms and building management organisations, delegates, postal providers or couriers assisting with the delivery of documents related to a situation, and the like
- Third-party service providers who assist us in operating and interpreting data obtained through the Google Analytics platform, manage our newsletter service, social media marketing, Adwords (Google Ads) or other similar online services
- Potential buyers of our business or parts of our business
Please note that this list is not exhaustive and there may be other instances where we need to share personal data with other parties in order to provide services as efficiently as possible or to protect the rights, safety, property of our company or its employees, suppliers or others, to respond to complaints or to prevent fraud and illegal activities.
9. Third party contractors and other operators
As mentioned above, we may appoint sub-contractors as necessary to deliver the services, such as, without limitation, firms providing consulting services of various specialties, document processing, accounting, confidential waste disposal, training, computer systems and software providers, IT support service providers, document and information storage service providers, cloud providers, marketing agencies, PR, advertising, advertising production, event organisation, human resources and payroll companies, security firms and building management bodies, proxies, postal providers or couriers assisting us with the delivery of documents related to a situation and the like, who will process personal data on our behalf and under our direction. We carry out due diligence and put in place the necessary contractual documentation in relation to any sub-contractors to ensure that they process personal data appropriately and in accordance with legal and regulatory obligations.
Further, we may appoint external personal data processors where necessary for the delivery of services (for example, but without limitation, accountants or other third party experts), while complying with legal and regulatory obligations with respect to personal data, including, but not limited to, the implementation of appropriate safeguards.
We may also transfer and share this information, in accordance with applicable law, to affiliates or partners when it is in our legitimate interest to do so.
10. Where do we transfer personal data?
In order to provide the services or for other processing purposes listed here, we may need to transfer your personal data to locations outside the European Economic Area. In any case, before transferring personal data to another location outside the European Economic Area, we will ensure that there is a decision on the adequacy of the level of protection or that the controller or processor in that location provides adequate safeguards or one of the following exceptions applies:
- you have explicitly agreed to the proposed transfer, having been informed of the possible risks that such transfers may entail;
- the transfer is necessary for the performance of a contract between you and us or for the enforcement of pre-contractual measures taken at your request;
- the transfer is necessary for the conclusion of a contract or the performance of a contract concluded in your interest between us and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for the establishment, exercise or defence of legal claims;
- the transfer is necessary for the protection of your vital interests or those of others, when the data subject lacks the physical or legal capacity to consent.
- the transfer is made from a register which is intended to provide information to the public and which is open to public inspection
11. How long we keep your personal data
We retain the personal data we collect from and about you for as long as necessary to fulfill the purpose for which we collected it and to satisfy any legal, accounting or reporting requirements under our Retention Schedule. In determining the appropriate retention period for the personal data we process, we take into account the nature, scope, context and purposes of the processing, the risks of varying degrees of likelihood and severity to your rights and freedoms, applicable legal, accounting or reporting requirements, and whether we can achieve the purposes of the processing by other means.
Upon expiration of retention periods, we may destroy such files without further notice or liability.
12. Privacy and security of your personal data
We implement appropriate technical, physical and organisational measures that are reasonably designed to protect personal data against destruction, loss, alteration, unauthorised disclosure or access and other unlawful forms of processing. Access to personal data is limited to authorised recipients on a need-to-know basis. We maintain a comprehensive information security program commensurate with the risks associated with processing. The programme is continuously adapted to mitigate operational risks and protect personal data, taking into account accepted practices in the field. We also use enhanced security measures when processing any special categories of personal data.
All our partners, employees, consultants, workers, processors and processors (i.e. those who process your personal data on our behalf for the purposes listed above), who have access to and are associated with the processing of personal data, are obliged to respect the confidentiality of this personal data and to guarantee the same level of protection as that provided by the company.
13. Right of access and other rights
You have the following rights in relation to the personal data we process or hold about you:
a) Right of access
If you ask us, we will confirm whether we are processing your personal data and, if permitted by law, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee based on administrative costs.
b) Right of rectification
If the personal data we hold about you is inaccurate or incomplete, you have the right to request its rectification. If you have the right to rectification and if we have shared your personal data with others, we will inform them of the rectification if possible. If you ask us, where it is possible and legal to do so, we will also tell you with whom we have shared your personal data so that you can contact them directly.
c) Right of erasure
You can ask us to delete or suppress your personal data in certain circumstances, such as if we no longer need it. If you have the right to erasure and if we have shared your personal data with others, we will inform them of the erasure where possible. If you ask us, where it is possible and lawful to do so, we will tell you with whom we have shared your personal data so that you can contact them directly.
d) Your right to restrict processing
You can ask us to “block” or stop processing your personal data in certain circumstances, such as if you dispute the accuracy of that personal data or have objected. If you have a right to restriction and if we have shared your personal data with others, we will inform them of the restriction where we are able to do so. If you ask us, where it is possible and lawful to do so, we will also tell you with whom we have shared your personal data so that you can contact them directly.
e) Right to data portability
You have the right, in certain circumstances, to obtain the personal data you have provided to us, in a structured, commonly used and machine-readable format, and reuse it elsewhere or ask us to transfer it to a third party of your choice.
f) Right to object
You can ask us to stop processing your personal data and we will do so if:
- We rely on your legitimate interests or those of third parties to process personal data, unless we can demonstrate compelling legitimate grounds justifying the processing
- The processing is necessary for the performance of a task carried out in the public interest, unless we can demonstrate compelling legitimate grounds for the processing
- We process your personal data for direct marketing purposes
TTS will never use your personal data to subject you to an automated individual decision.
g) Your right to withdraw your consent
If we rely on your consent (or explicit consent) as the legal basis for processing your personal data, you have the right to withdraw this consent at any time.
h) Your right to lodge a complaint with the supervisory authority
If you are concerned about any aspect of our privacy practices, including our handling of your personal data, you may report it to the relevant supervisory authority.
Please note that some of these rights may be limited where we have a legitimate interest or legal obligation to continue processing the data or where the data may be exempted from disclosure for reasons related to obligations of professional secrecy or disclosure involves personal data of third parties.