Privacy is at the core of what we do. We understand the importance of trusting your suppliers with your documents and have therefore put in place measures to ensure that your data is safe with us, at all times. This privacy policy will give you information on how we collect and process your personal data, how long we keep it for, and your rights as a customer. Personal data refers to any information about an individual that can be used to identify them. This privacy notice applies to the provision of language services covered by us. We would like to encourage you to read this policy carefully and to contact us in case of any questions or concerns about our privacy practices.

Who are we?

Please find below our contact details:

Name: Elena Ferrara

Email address: info@elenaferrara.eu

Website: www.elenaferrara.eu

Phone number: +44 7796598495

What information do we collect?

For the purposes of the provision of language services, we may need to collect personal information about yourself, in the form of phone conversations, email content and written documents submitted to us to place an order with us. This data includes but is not limited to: names, company names, addresses, email addresses, dates and places of birth, civil status, payment and transaction data (when you place an order with us), etc.

We collect data via the use of our services, in the form of written exchanges. The data is typically present in documents sent across for translation.

Any personal information that is sent to us in the form of a written document is saved on an encrypted computer. Emails are sent and received via Gmail, which uses HTTPS encrypted connections. Where large files need to be sent, they will either be transferred using Google Drive or WeTransfer.

We cannot be held responsible for the security of the data that is sent to us until it reaches our system.

How do we use personal information?

Data is being processed for the purpose of providing our customers with language services, including but not limited to: translation, proofreading, transcription, quality assurance, project management and interpreting.

Translation Memory: We may create a Translation Memory (TM) for your projects. A Translation Memory stores repeated words and phrases to ensure consistency across files. We may also use your translations to contribute to building up our own industry-specific TMs and glossaries. Please contact us if you would prefer to be quoted without the benefits of TM support.

What legal basis do we have for processing your personal data?

Our legal basis is the contract we have entered into with yourself, i.e. the provision of language services. By sending us content, you are providing consent to us processing the data you send us for that same purpose, to the extent necessary.

We also need to process data to comply with legal obligations, such as keeping accurate records of all transactions received.

When do we share personal data?

Personal data is treated confidentially and is only shared with one of the following:

• HMRC or other regulatory authority
• External suppliers who have signed our non-disclosure agreement and agreed to our privacy policy for the purpose of providing you with language services

The same IT infrastructure as described above for customer communication is used with our suppliers.

Where do we store and process personal data?

The vast majority of our work is done in the UK or in other EEA countries. However, on occasion, we may need to process your data overseas. This will typically be (i) to offer you superior services or (ii) to support faster turnaround. We will never process data outside the EEA without your permission.

The EEA is the European Economic Area, which includes the EU Members States, Liechtenstein, Iceland and Norway.

Should we need to transfer any of your data outside of the EEA, we will ensure that the following is put in place:

• Where the country has been deemed to have adequate protection by the European Commission, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Should we need to transfer some of your data to a country not listed above, we will only do so in order to confirm your order and process your project.

How do we secure personal data?

Personal data is mostly kept in an electronic format only, in line with the IT infrastructure described above. Where required, printing of data will take place for the purpose of providing our customers with certified translations. Our correspondence includes specifically that all hard copies are sent by first class post. Please note that we cannot be held responsible for processing of data by third party organisations (such as Royal Mail) outside of our remit.

Should additional security measures be required by our customers, we are happy, for a fee, to send hard copies via different means, such as tracked deliveries or courier.

How long do we keep your personal data for?

Please find below a table listing the type of data we collect and our retention schedule. All data is collected with the purpose of providing language services to our customers.

Group of data	Storage location	Retention period
Emails	Google mail	10 years
Customer documents (birth certificates, marriage certificates, etc.)	Dell XPS 13 (serial No. 34406984918) or equivalent	5 years
Payment and transaction data	Natwest bank account	As required and enforced by Natwest
Transit data (used fortransferring larger documents)	Google drive / WeTransfer	Temporary for transit only
Back-up of essential data	Dell XPS 13 (serial No. 34406984918) or equivalent and Black Blaze	As required by HMRC

Once the retention period has elapsed, data will be securely erased, using either Google Mail’s “trashbox” and “empty trashbox” functions, or using the Dell’s “bin” and “empty bin” functions.

Your rights in relation to personal data

Under the GDPR, you have the right to access and control your personal data. Specifically, you have the right to:

• access any personal information held about you. No fee will be charged for this, unless we find your request to be unfounded, repetitive or excessive.
• correct and delete any personal data held about you. We will then endeavour to look into this and correct the information if necessary.
• withdraw your consent for the processing of your data. You are welcome to do this at any time; please note that this may impact our service provision to you in the future.
• request a transfer of your data to a third party
• restrict the processing of your data and object to our use of your data
• lodge a complaint with the Information Commissioner’s Office

Subject data requests will be replied to within 28 calendar days – our contact details are listed below. Exemptions may apply where data is already being processed for the purpose of the provision of language services, where we would charge for the time already spent on the assignment prior to concluding it.

Data subject rights may be limited in cases where you are requesting us to delete data which we are required to keep by law.

How to contact us?

In case of any questions or concerns about our privacy practices, or if you have a complaint to make about the way your data has been handled, please do not hesitate to get in touch with us at the following:

Name: Elena Ferrara

Email address:info@elenaferrara.eu

Phone number: +44 7796598495

You also have a right to complain directly to the Information Commissioner’s Office, details of which can be found online at www.ico.org.uk. We value you and would appreciate the opportunity to address your concerns before you contact the ICO, so please get in touch with us first.