Privacy & Data Policy


1. INTRODUCTION

1.1    We are committed to safeguarding the privacy of our website visitors and customers.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4    In this policy, “we”, “us” and “our” refer to Sure Languages Ltd and its data controllers. For more information about us, see Section 12.

2. HOW WE USE YOUR PERSONAL DATA

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;
(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c)    the purposes for which we may process personal data; and
(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and online services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is monitoring and improving our website and services.

2.3    We may process your personal data that are provided in the provision of our services (“service data“). The service data may include your name, email address, company name, phone number, project information, and/or documents about your current or upcoming project. The source of the service data is from you or your employer. The service data may be processed for the purposes of providing our services. The legal basis for this processing is consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4    We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering relevant services to you. The legal basis for this processing is consent.

2.5    We may process information relating to transactions, including those for purchased services, that you enter into with us (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records. However, sensitive transaction data is not stored on our system or retained in any way. The legal basis for this processing is taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.

2.6    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.7    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. PROVIDING YOUR PERSONAL DATA TO OTHERS

3.1    We may disclose your company name or contact name to our subcontractors insofar as reasonably necessary for the provision of our services to you.

3.2    Financial transactions relating to website orders or payment by card for services are handled by our payment services provider, Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/legalhub-full

3.3    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    Subcontractors, such as our freelance linguists are situated in various countries around the world. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

4.3    You acknowledge that personal data that you submit through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. RETAINING AND DELETING PERSONAL DATA

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain your personal data as follows:

(a)    Usage data will be retained for a minimum period of 25 months following the date you visited our website. This is determined by Google Analytics terms and conditions.
(b)    Enquiry data will be retained for a minimum period of 1 month and for a maximum period of 1 year following an enquiry. Retention of this information allows us to more quickly meet the needs of customers.
(c)    Service data will be retained for a minimum period of 1 year following the provision of any services.

5.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of notification data will be determined based on when you unsubscribe to our communications.

5.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. AMENDMENTS

6.1    We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

7. YOUR RIGHTS

7.1    Your principal rights under data protection law are:

(a)    the right to access;
(b)    the right to rectification;
(c)    the right to erasure;
(d)    the right to restrict processing;
(e)    the right to object to processing;
(f)    the right to data portability;
(g)    the right to complain to a supervisory authority; and
(h)    the right to withdraw consent.

7.2    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 10); and
(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

7.3    We may withhold personal information that you request to the extent permitted by law.

7.4    You may instruct us at any time not to process your personal information for marketing purposes.

7.5    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

8. ABOUT COOKIES

8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. COOKIES THAT WE USE

9.1    We use cookies for the following purposes:

(a)    Authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b)    Analysis – we use cookies to help us to analyse the use and performance of our website and services.

10. COOKIES USED BY OUR SERVICE PROVIDERS

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

11. MANAGING COOKIES

11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)    https://support.apple.com/kb/PH21411 (Safari); and
(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

11.3  If you block cookies, you will not be able to use all the features on our website.

12. OUR DETAILS

12.1  This website is owned and operated by Sure Languages Ltd.

12.2  We are registered in England and Wales under registration number 06058494, and our registered office is at Generator Quay House, Kings Wharf, Exeter EX2 4AN.

12.3  Our principal place of business is at Generator Quay House, Kings Wharf, Exeter EX2 4AN, and at 83 Princes Street, Edinburgh, EH2 2ER.

12.4  You can contact us:

(a)    by post, to the postal address given above;
(b)    by email, by the email address published on our website from time to time;
(c)    by telephone, on the contact number published on our website from time to time.

13. DATA PROTECTION OFFICER

13.1  Our data protection officer’s contact details are: The Data Officer, Sure Languages Ltd, Generator Quay House, Kings Wharf, Exeter EX2 4AN. Email: privacy@sure-languages.com