I am Elizabeth Broom, trading as Eurolinguist Translation Solutions, and I am committed to maintaining the trust and confidence of visitors to my website, clients, colleagues and suppliers.
I comply with the New Zealand Privacy Act 1993 (the Act) when dealing with personal data. Personal data is information about an identifiable individual (a natural person).
This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.
I also comply with the EUROPEAN GENERAL DATA PROTECTION REGULATION (EU) 2016/679 (GDPR). You may contact me in my capacity as Data Controller of the data under my powers, duties and liabilities, according to the above regulation, via email at email@example.com.
CHANGES TO THIS POLICY
I may change this policy by uploading a revised policy onto the website. The change will apply from the date that I upload the revised policy.
WHO PROVIDES YOUR PERSONAL DATA
I collect personal data about you from:
you, when you provide that personal data to me, including via the website and any related service, through any registration or subscription process, through any direct contact with me (e.g. telephone call, text or online messaging, or email), or when you request or purchase my services
third parties where you have authorised this or the information is publicly available.
If possible, I will only collect personal data from you directly.
HOW I USE YOUR PERSONAL DATA
The legal basis for processing your data is to perform the services you request or to take necessary steps prior to fulfilling that request, and to comply with legal requirements.
I hold data on clients, suppliers, collaborators, data processors and potential clients for legitimate interests.
Personal data may include your name, postal address, email address, telephone number, tax, social security or ID number, payment and delivery conditions, or financial and bank account details.
I collect, store and use such personal data for the purposes of issuing a quotation, providing any translation, editing, revision, consulting or interpreting services that you request and consent to, invoicing or receiving payment, and verification of name spellings or other text ambiguities. I may also collect, store and use such personal data for providing reprints of translations, complying with legal and taxation requirements, or I may store anonymised texts for my own future reference.
I will not use your personal data for marketing purposes that are not relevant to our business relationship. I may use it to respond to any communications from you (including a complaint), to inform you of any future promotions or updates to my services, to communicate with you following the completion of a service in order to request feedback or reviews, improve my services and processes or to optimise your experience in the case of on-going collaborations. I may also use this data to protect and/or enforce my legal rights and interests, including defending any claim, or for any other purpose authorised by you or the relevant legislation.
The data in question will be retained throughout the business relationship only, or for the length of time stipulated to comply with legal or taxation obligations.
DISCLOSING YOUR PERSONAL DATA
I may disclose your personal data to a trusted colleague for revision, editing, translation services and clerical or administrative support, in which case the text will either be anonymised so that your personal data does not appear, or that colleague will be asked to sign a confidentiality agreement. Any such colleague will be advised of their legal obligations in relation to confidentiality and professional secrecy. I may also disclose your personal data to a person who requires me to supply your personal data (such as a regulatory authority), any other person authorised by the relevant legislation or another law (such as a law enforcement agency) or any other person authorised by you.
A business that supports my services may be located outside New Zealand. This may mean that your personal data is held and processed outside New Zealand. Other parties that may have access to your personal data for administrative purposes include my website, email hosting service, PayPal and online accounting or invoicing tools, cloud storage providers and Google Suite applications. All of these parties are GDPR-compliant (please also see the section on security measures below).
RETENTION OF PERSONAL DATA
Data relating to quotes will be retained for up to six months. In cases of work carried out, I am obliged to retain your personal data in electronic format for seven years to comply with local taxation obligations, after which period this data will be deleted using a secure digital file eraser utility. I will also delete email communication after seven years.
If physical copies of translations and their corresponding source documents containing personal data are not required or requested by clients, these will be destroyed using an electronic shredding machine within one month of their date of issue.
PROTECTING YOUR PERSONAL DATA
I will take reasonable steps to keep your personal data safe from loss, unauthorised activity, or other misuse, in compliance with the New Zealand Privacy Act 1993.
Pursuant to the European General Data Protection Regulation (EU) 2016/679, I will take all precautionary steps to guarantee the security, integrity and confidentiality of your personal data in relation to the processing of personal data and the free movement of such data.
Your rights and obligations
Visitors to my website are not obliged to provide personal data. Nevertheless, any individual interested in my services may contact me via the contact information provided, and some personal data will need to be collected in order to establish communication.
You have the right to opt out of receiving any direct marketing communications from me.
You are entitled to access, modify, erase or contest the personal data that I hold, in accordance with the abovementioned EU regulation. Please send your request directly to me at firstname.lastname@example.org and I will act upon this as soon as possible, within a maximum of one month from the date of your request.
Please also contact me at the above email address if you have any concerns about how I process your personal data. You also have the right to lodge a complaint with the supervisory body in New Zealand or in the country in which you live.
For non-EU clients, subject to certain grounds for refusal set out in the New Zealand Privacy Act 1993, you have the right to access your readily retrievable personal data that I hold and to request a correction to your personal data. Before you exercise this right, I will need evidence to confirm that you are the individual to whom the personal data relates.
In respect of a request for correction, if I believe the correction is reasonable and I am reasonably able to change the personal data, I will make the correction. If I do not make the correction, I will take reasonable steps to note on the personal data that you requested the correction.
If you wish to exercise either of the above rights, email me at email@example.com. Your email should provide evidence of who you are and set out the details of your request (such as the personal data or the correction that you are requesting).
I may charge you my reasonable costs of providing to you copies of your personal data or correcting that data.
I take all possible precautionary measures to guarantee that your personal data is safeguarded.
Updates to computers and devices: The equipment used for storing and processing personal data is updated as frequently as possible.
Malware: Anti-virus software is installed on the equipment used for storing and processing personal data, to prevent the theft or destruction of this data. This anti-virus software is regularly updated
Firewall: Firewalls are in place on all devices used for storing or processing personal data, to avoid remote unlawful third-party access.
Back-up: Personal data is periodically backed up on a device other than that used on a day-to-day basis. The copy is stored in a secure place, separate from the computer containing the original files, so that personal data may be recovered in the event of loss or damage. Should this back-up be carried out via electronic methods, an encrypted method is used to guarantee the confidentiality of the personal data in the event of unlawful third-party access.
Technical measures: All electronic systems in use for storing or processing personal data are password protected.
Breaches of personal data
In the event of a security breach of personal data due to theft or unlawful access, for example, I will notify the individual(s) affected and the New Zealand Office of the Privacy Commissioner within 72 hours of this security breach. This will include all of the data necessary to clarify the circumstances under which this happened. Notification will be carried out electronically via the online Privacy Commissioner portal:
While I take reasonable steps to maintain secure internet connections, if you provide me with personal data over the internet, the provision of that data is at your own risk.
The data collected includes pages viewed and your journey around the website. These cookies are not used to collect or record data on your name, address or any other contact details.
Accept cookies: Once you accept cookies the warning message will no longer appear on any of the website’s pages throughout the same session.
Close: The message will disappear within the existing webpage.
Based on my legitimate interest (that is, my interest in analysis, optimisation and economic performance of my online offer in accordance with Article 6, Section 1, Letter F of the GDPR), I use a third-party service, Google Analytics, which is Google LLC’s web analysis service.
Google Analytics collects standard internet log data and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This data is only processed in a way that does not identify anyone. I neither make nor allow Google to make any attempt at discovering the identities of those visiting my website.
The user information generated by Google cookies regarding my online offer is normally transferred to a server and stored in the USA. Google is certified by its Data Processing Agreement for Europe, and therefore guarantees compliance with European data privacy regulations.
If you are not happy about this, please click the following link to obtain the Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout
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