As a professional freelance translator and language consultant I am committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why I collect personal information, how I use it, the limited conditions under which I may disclose it to others and how I keep it secure. This Privacy Statement applies to the use of my services and to my sales, marketing, customer contract fulfilment activities, and Italian business regulations fulfilment activities.
Important: this Privacy Statement was updated on 20th May 2018 and will be reviewed as and when necessary. Should any differences occur between the various language versions, the Italian language version will prevail.
1. Who I am
I am a freelance translator and language consultant, supporting my clients to fulfil their language needs and to bridge both language and cultural gaps.
I am a registered professional entrepreneur – you may contact me in my capacity as Data Controller of the data under my powers, duties and liabilities, which according to EUROPEAN GENERAL DATA PROTECTION REGULATION (EU) 2016/679
Via Loreto n. 131, 00036 Palestrina (RM), Italy
Or via email at email@example.com
2. I collect personal data about you when…
• When you require to use my services.
• When you interact with me through correspondence, by phone, by social media, through my website, or in person.
• I may collect personal information from other legitimate sources, such as public sources or social networks. I only use this data if they are public, i.e. you have given your consent to them to share your personal data with others.
• I may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected I make sure an assessment is made, ensuring that there is an established mutual interest between us.
3. Why do I collect and use personal data?
I collect and use personal data mainly to perform work activities you request and tasks we agree upon, to inform you about any disruption or change in my activity, for marketing purposes about my services, for customer service, and to comply with Italian business regulations.
I may use your information for the following purposes:
• Send you replies, communications, quotes, invoicing, translations or other content based on required services.
• Reply to a ‘Contact me’ form you have completed on my website.
• Follow up on incoming requests (customer support, emails, chats, or phone calls).
• Perform contractual obligations such as order confirmations, license details, authorizations, invoices, reminders, and similar.
• Notify you about any disruptions to my services or related changes.
• Contact you for feedback about your opinion on my services.
• Process a job application.
4. Legal basis for collecting personal data
4.1. Collecting personal data based on consent
The collection of personal data based on consent from the data subject will be done by requesting your consent – individual consents will always be stored and documented in my systems.
As specified in my signature, replying to my emails will be considered as consent for your personal data to be collected as managed according to this Privacy Statement, unless you require not to.
4.2. Collecting personal data based on purchase orders, agreements, and contracts
I use personal information for fulfilling my obligations related to purchase orders, agreements, and contracts with customers, partners and suppliers.
4.3. Collecting personal data based on legitimate interest
I may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. This includes fulfilling Italian business regulations – including, but not limited to, tax and fiscal regulations, as well as accountancy requirements. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between the individual person and myself as a professional has been identified. I will always inform individuals about their privacy rights and the purpose for collecting personal data.
5. Type of personal data I collect
Personal data collected may include your name, phone number, job title, email address, postal address, in addition to your company name, contact information, tax ID and fiscal details for invoicing purposes, payment and delivery conditions, financial and bank account details.
I may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails.
I do not collect information from your activity on my website, except for the cookies listed here
6. Personal data storage
I take all possible precautionary measures to guarantee that your personal data is safeguarded.
Your personal data in digital form are stored in a password-protected external hard disk and in its backup disk, stored in a secure place, separate from the main hard disk containing the original files, so that personal data can be recovered in the event of loss or damage. Emails are stored in Google G-Suite servers hosting my professional email and in any other portal you may require to perform the tasks agreed upon.
Copies of emails might be stored in my mobile phone with iOS protection and encryption.
Business cards are stored in a dedicated space in my office, not accessible from third parties.
7. Retention of personal data
I store personal data for as long as I find it necessary to fulfil the purpose for which the personal data was collected, while also considering my need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that I may retain your personal data for a reasonable period of time after your last interaction with me. When the personal data that I have collected is no longer required, I will delete it in a secure manner.
8. Your rights to your personal data
You have the following rights with respect to your personal data:
• The right to request a copy of your personal data that I hold about you.
• The right to request that I correct your personal data if inaccurate or out of date.
• The right to request that your personal data is deleted when it is no longer necessary for my business to retain such data.
• The right to withdraw any consent to personal data processing at any time.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
Any query about your Privacy Rights should be sent to firstname.lastname@example.org - I will act upon this as soon as possible, within a maximum of one month from the date your request is received.
I do not collect neither any personal information from your activity on my website, nor how you interact while navigating my website, except for the cookies used by my website hosting and provider, as per the list in this link https://support.wix.com/en/article/cookies-and-your-wix-site
My website includes buttons connected to social media and/or other associations – their own privacy statements and rules apply to any personal data collection deriving from your interaction with them.
10. Sharing data with others and third party access
I do not sell, rent, or trade your information with any third parties.
For administrative purposes, I have contracted a professional company for accountancy, administration and tax advice. In case you need to have information about that company, please contact me – contact details in paragraph 1.
Other parties may have access to your personal data for administrative purposes, including my website and email hosting services. All these parties are GDPR-compliant.
11. In the event of a data breach
In the event of a security breach of personal data, due to theft or unlawful access for example, if the breach implies risks for freedom and/or rights of subjects affected, I will notify both those subjects and the Italian Data Protection Agency within 72 hours of this security breach. This will include all of the information necessary to clarify the circumstances under which this happened.
12. Changes to this Privacy Statement
I reserve the right to amend this Privacy Statement at any time. The applicable version will always be found on my website. I encourage you to check this Privacy Statement occasionally to ensure that you are happy with any changes.
If I make changes that significantly alter my privacy practices, I will notify you by email or post a notice on my websites prior to the change taking effect.
I hope that you won’t ever need to, but if you do want to complain about my use of personal data, please send an email with the details of your complaint to email@example.com. I will look into and respond to any complaints I receive. You also have the right to lodge a complaint with the supervisory body in Italy or in the country where you live.