Last modified: 09.08.2017
When collaborating with Travod International Ltd. (“Travod”), your personal data is processed in order to carry our daily operations and requirements as a translation-providing company. In the framework of these processing operations, we ensure that your data is protected according to the highest standards, namely in accordance with respective laws and the provision of EU Regulation 2016/679, known as the General Data Protection Regulation (GDPR). This Privacy Notice describes the ways in which Travod processes, protects, and ensures your rights as a data subject.
I. Purposes of processing
Travod receives your personal data when you use our Online Registration form and/or when you share your personal data by e-mail. We store and use this data for the following purposes:
- align your abilities and the linguistic skills with the translation services requested by our clients;
- check your availability to respond to a translation request;
- contact you with regard to the services provided to Travod as a vendor;
- transmit requests from clients and materials related to it;
- evaluate your performance for future management and collaboration; and
- process payments for the services thus provided.
II. Legal grounds for personal data processing
Travod will process your personal data when there is a legal basis to do so. In accordance with the current GDPR requirements and provisions, we will lawfully process your data only when need the data:
- in order to fulfil an agreement between you, as a vendor, and Travod;
- to comply with an obligation under applicable laws;
- you have consented to our use of it for a specific purpose;
- to pursue our legitimate interest, which we consider to be the creation and maintenance of a database of vendors, to generate statistics pertaining to vendors and clients, and to continuously improve our services; thus, we will use your data only for the above purposes as long as your interests and fundamental rights do not supersede such usage; and
- to protect your vital interests or those of another individual.
III. Categories of personal data we process
After establishing the purposes and the adapted legal bases for personal-data processing operations, we determine what categories of personal data we use. In this regard, we process the personal data categories enumerated in the table below. This list is not exhaustive, however it provides the main vendor’s personal data categories processed by us in our day-to-day operations.
|General information||Financial information||Work performance|
Personal data categories
Extracted from your Curriculum Vitae, from various professional public profiles and/or entered into our online registration form: name, surname, date of birth, education, e-mail, phone number, address, professional experience, references, price rates;
Bank, PayPal account, Skrill account, TransferWise account, national identification number;
Number of projects, words per day, ratings based on feedback from clients, other translators or from our experts;
IV. Storage, retention and erasure of personal data
The personal data used by Travod is stored in our Translation Management System. In general, storage periods at Travod are based on criteria which include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, and any operational directives or needs.
To limit the storage to a reasonable period, the vendor’s personal data will be stored as long as an active relation exists between you and Travod, meaning that assignments are given at least once in a two years’ time. After the expiration of this period, Travod can store your data only to comply with legal provisions, for ongoing or future litigations and to execute active contracts. Once all these purposes have been satisfied, your personal data will be deleted or otherwise processed so as to render your identity anonymous.
V. Transfers of personal data
Transfers to third parties
Travod may transfer personal data to third parties in certain circumstances. In general, these transfers are related to two main instances:
- transfers to clients, with the vendor’s explicit consent or when fulfilling contractual or legal obligations (e.g., for the execution of a contract); and
- transfers to public authorities or law-enforcement agencies, upon request or for the fulfilment of legal requirements.
During its activities, Travod does not receive vendor-related data from third parties.
International transfers to third countries
Due to the internal organization of Travod’s operations, certain of our teams are located outside of the European Economic Area (EU member states plus Iceland, Norway and Liechtenstein). Therefore, your personal data may be transferred outside the EEA to countries without adequacy decision from the European Commission. However, we ensure EU-level data protection through the use of standard contractual clauses to guarantee the security of your data.
VI. Data protection rights
Right to access your personal data
At any time, you may submit a request to obtain information concerning the details of how and why we process your personal data. In addition, you are entitled to know for how long we store and who receives your personal data. This right to access can be however restricted in order to protect other persons’ private life, because of business considerations (e.g., to protect our expertise, business secrets) and by legislation.
Right to rectification and erasure of data
In case your data is incorrect, incomplete or inaccurate you may request from us to correct it. If the personal data we process about you is irrelevant, you may request Travod to delete it. This right is applied in accordance with the existing legislation and GDPR considerations.
Right to restriction of use
You are entitled to demand from us to restrict the use of your personal data in case you claim that the personal data we possess about you is incorrect, incomplete or in case you objected to us processing it. The restriction will limit the use of your data to solely storage and will last until the correctness of the data is established or if it is determined that your interest outweighs our legitimate interest. If you are entitled to have the data we have about you erased, you may instead request us to restrict the use of these data to storage.
Right to object and automated decision-making
When invoking our legitimate interest, carrying out a task in the public interest or when pursuing the purposes of direct marketing, you may object to Travod processing your personal data. The processing operations will be restricted to storage, as described in the preceding paragraph.
This right also extends to decisions based solely on automated processing, inclusive of profiling. For these cases we reserve the right of human intervention in order to review such cases.
Right to data portability
In situations when we process automatically your personal as a result of a consent or agreement, you are entitled to receive a copy of the data you have provided in an electronic, machine-readable format.
Withdrawal of consent
In cases when we use your consent as the legal basis to process your data, you have the right to withdraw your consent at any point during such processing. However, Travod can continue to process your personal data lawfully if fulfilling a contractual or a legal obligation.
VII. Accuracy and updating your personal data
For as long as your personal data is stored in our internal systems, we will ensure that this data is permanently updated, in order to ensure its accuracy. This practice is implemented to respond to GDPR’s requirement but also to enable the necessary adequacy between your professional profile and the requests from our clients. Therefore, you will be able to update directly the information about your profile on Translation Management System or by informing our responsible person at email@example.com.
VIII. Updates to this privacy notice
This Privacy Notice may be routinely revised in order to respond to potential evolutions in our processing operations or to external regulatory changes. In this context, an updated version will be posted on our website. In the event of any significant changes which may substantially reduce your rights or increase your obligations, we will inform you by e-mail or on the inform you by e-mail or through our Translation Management System. We recommend a periodic review of this page for current information in regards to our privacy practices.
IX. Contact details and complaint submission
If you have any queries in regards to your privacy rights or the manner in which we process your personal data, you are welcome to contact Travod at our offices located at 49 Queen Victoria Street, London EC4N 4SA, United Kingdom or via e-mail at firstname.lastname@example.org.
If you aren’t satisfied with the modalities by which Travod processes your personal data or aren’t satisfied with your interaction with our responsible person, then you may lodge a complaint with the Information Commissioner’s Office (ICO), United Kingdom’s data-protection authority.
ICO contact details:
Information Commissioner’s Office
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel.: 0303 123 1113
Contact form: https://ico.org.uk/global/contact-us/e-mail/