June, 2020

At TRANSLIT we are committed to protecting and respecting your privacy

This Privacy Policy will let you know how we look after your Personal Data with regard to your use of this Platform and in the context of receiving marketing communications from us. It also informs you as to our obligations and your rights under data protection law.

This Privacy Policy applies to Users of thePlatform and visitors to the Website.

If you are aged 16 or under you should not use this Platform nor should you provide any personal information to us via the website.


In this Privacy Policy the following words have the following meanings:

“Data Controller” means the person who or organisation which determines the purposes for which, and the manner in which, any Personal Data is processed, who/which makes independent decisions in relation to the Personal Data and/or who/which otherwise controls that Personal Data;

“Data Processor” means the person who processes Personal Data on behalf of the Data Controller;

“Data Subject” means a natural person whose Personal Data is processed by a Data Controller or Data Processor;

“GDPR” means the EU General Data Protection Regulation (EU Regulation 679/2016);

“User Account” means a person and/or organisation (Agency, Freelancer, Business Client and/or Individual Client)engaging with the TRANSLIT Platform pursuant to the Terms;

“Service” means all or any of the services provided by TRANSLIT to Users through the website ( (and “Services” shall be construed accordingly);

“Sub-Processor” means any person or entity appointed by or on behalf of the Data Processor to process Personal Data on behalf of the Data Controller;

“We”, “Our” or “TRANSLIT” means the “Company” Freelance Providers Limited T/A TRANSLIT.

The headings below detail an overview of how we collect and process your Personal Data in connection with your use of the TRANSLIT website and for marketing purposes:

  • Who is responsible for your Personal Data?
  • What Personal Data do we collect?
  • How do we collect your Personal Data?
  • For what purposes do we process your Personal Data and what is our legal basis?
  • Data Portability
  • Do we share your Personal Data with anyone else?
  • Keeping your Personal Data secure
  • For how long do we keep your Personal Data?
  • Your data protection rights
  • Cookies we use and their purpose
  • Contact us
  • Updates to this Privacy Policy
  1. Who is responsible for your Personal Data?
    • TRANSLIT acts as the Data Processor:

      Accounts: For the purposes of GDPR, User Accounts provide Personal Data relating to their own accounts and where applicableAdministrators provide the information relating to Managers of the sub-accounts, TRANSLIT is the Data Processor with regard to such Personal Data.

      If you have any questions about this policy or about our data protection compliance please contact us.

    • The User Account acts as the Data Controller and TRANSLIT as the Data Processor.

      It may be necessary as part of an engagement for a User to provide a Service Provider with personal data pertaining to third parties who are not Users of the Platform. In that instance, TRANSLIT is a Data Processor of such Personal Data and the User providing such information is the Data Controller.

    • Administrator Accounts will also be responsible for:

      • informing its Manager Accounts of its privacy policy and practices, including, the lawful grounds upon which the Administrator Account is processing any Personal Data;
      • compliance with data protection laws;
      • drawing the Manager’s attention to this Privacy Policy as well as implementing all the necessary protocols required for their industry; and
      • handling any and all requests in respect of data portability, data transfer and data access requests.

      As a Data Controller, the User will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of any Personal Data to us for the duration and purposes of the use of the TRANSLIT Platform.

      As a Data Processor, we will:

      • Process that Personal Data only on the written instructions of the User unless we are required by the laws of any member of the European Union or by the laws of the European Union applicable to us to process Personal Data (“Applicable Laws”);
      • Ensure that we have in place appropriate technical and organisational measures, to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, as are appropriate;
      • Ensure that our staff who have access to and/or process Personal Data are obliged to keep the Personal Data confidential;
      • Ensure that where a Sub-Processor is used, we shall:
        • Inform the Users of any intended changes concerning the addition or replacement of Sub-Processors;
        • Implement a written contract containing the same data protection obligations as set out in the agreement we entered into with the Users pursuant to the Terms, in particular providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of the Applicable Laws;
        • Understand that where any Sub-Processor is used on their behalf, that any failure on the part of the Sub-Processor to comply with the Applicable Laws or the relevant data processing agreement, we, as the initial Data Processor, remain fully liable to the User for the performance of the Sub-Processor’s obligations;
      • Not transfer any Personal Data outside of the European Economic Area unless one of the safeguards described in bullet point 4 above is in place;
      • Assist the User, at their cost, in responding to any request from a Data Subject and in ensuring compliance with its obligations under the data protection laws with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
      • Notify the User without undue delay on becoming aware of a Personal Data breach;
      • Within 24 months of the date of termination or cancellation of a User delete the Personal Data and copies thereof unless required by Applicable Laws to store the Personal Data; and
      • Maintain complete and accurate records and information to demonstrate our compliance with these obligations.

      We are not liable in respect of any Personal Data and in particular Personal Data relating to third parties which is controlled by the User in breach of data protection laws.

  2. What Personal Data do we collect?
  3. For Users

    We may collect, use, store and transfer different kinds of Personal Data about which we have grouped together as follows:

    • Identity Data includes first name, last name, username or similar identifier, title, date of birth.
    • Contact Data includes billing address, address, email address and telephone numbers.
    • Financial Data includes payment card details processed through Stripe (where applicable). For the avoidance of doubt, TRANSLIT does not and will not hold credit card details itself.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Usage Data includes information about how you use our website, products and services.
  4. How do we collect Personal Data?
  5. "Personal information" is any information that can be used to identify an individual or device, and may include things such as your name, physical address, email address, phone number, login information, marketing preferences, company affiliation, geographic location, or payment card information. TRANSLIT may collect personal information that is necessary for legitimate business purposes, which will be disclosed to you at the time of collection. TRANSLIT will use this information for the purposes for which it was collected. TRANSLIT may also collect personal information from trusted third-party sources and engage third parties to collect personal information to assist us. One of the most common methods of collecting personal information is during the online form submission or registration process, including where a website user is requesting a free trial or a courtesy newsletter, registering for an event, or responding to similar offers such as sample reports, white papers, or further product information. In some instances, TRANSLIT and the third parties we engage may automatically collect and aggregate data using cookies, weblogs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of our Platform and to help us tailor content or offers for you. Please read Section10 (Cookies) below for more information.

  6. For what purposes do we process Personal Data and what is our legal basis?
  7. TRANSLIT may use your personal information for operational, legal, administrative, and other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:

    • Providing you with requested products or services.
    • Providing you with information regarding similar products or events.
    • Analysing and monitoring extent of use.
    • Providing customised product and service information.
    • Allowing users to participate voluntarily in mailings or other events.
    • Providing product service updates, information, and alerts.
    • Sending communications, including for marketing or other customer satisfaction purposes.
    • Order processing and to provide transaction documents.
    • Analysing and monitoring extent of use and enhancing TRANSLIT’s Platform.

    When we process personal information for our and third parties’ legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you.

    We have considered whether there are other less intrusive means to reach the purposes identified above while still serving the legitimate interests identified.

    Our use of this personal data is subject to an extensive framework of safeguards that help make sure that people’s rights are protected. These include the information given to you on how your personal data will be used how you can exercise your rights to obtain a copy of your personal data, it corrected or restricted, object to it being processed, and complain if you are dissatisfied. These safeguards help sustain a fair and appropriate balance so that our activities do not override your interests, fundamental rights and freedoms.

    We use cookies to facilitate the use of our website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy here.

  8. Data Portability
  9. In the event of a termination of the relationship between the Company and a User. It will be the responsibility of the User to comply with the requirements of GDPR in accordance with their own protocols and procedures which they control. Otherwise, TRANSLIT will hold the necessary data pertaining to a User, in particular financial data for such period as may be in compliance with the requisite legislative requirements.

  10. Do we share your Personal Data with anyone else?
  11. We may share your Personal Data with the following parties in connection with our processing of your Personal Data:

    We require all third parties to enter into a data processing agreements with us which complies with our obligations under the GDPR. This agreement requires third parties to have appropriate security systems in place and only to use your Personal Data on our instructions and in accordance with data protection law.

    In rare circumstances, we may be obliged to disclose Personal Data if disclosure is required to comply with the law.

  12. Keeping your Personal Data secure
  13. We take appropriate security measures against unlawful or unauthorised processing of Personal Data, and against the accidental loss of, or damage to, Personal Data. We limit access to your Personal Data to those employees, agents and other third parties who are required to have access to your Personal Data and where they have agreed that they are subject to a duty of confidentiality.

    We have put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. We have procedures in place to deal with actual and suspected data breaches which include an obligation on us to notify the supervisory authority and/or you, the Data Subject, where legally required to do so.

    We do not transfer your Personal Data out of the European Economic Area, save as detailed herein.

  14. For how long do we keep your Personal Data?
  15. Your Personal Data will be deleted when it is no longer reasonably required for the purposes described above or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data.

  16. Your data protection rights
  17. Under certain circumstances, by law you have the right to:

    • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
    • Request access to your personal information (commonly known as a "Data Subject Access Request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
    • Request erasure of your personal information. his enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
    • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) nd there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • Request erasure of your personal information. his enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
    • Object to automated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you.
    • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    • Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
    • Withdraw consent: where we rely on consent as a legal basis, you may withdraw consent at any time by contacting us. Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

    In the event that you wish to make a complaint about how your Personal Data is being processed by TRANSLIT, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows:

    Data Protection Commissioner
    Telephone: +353 57 8684800/+353 761 104 800
    Post: Office of the Data Protection Commissioner
    Canal House
    Station Road
    R32 AP23 Co. Laois

  18. Cookies we use and their purpose
  19. We use four types of Cookies - ‘Strictly Necessary’, ‘Performance’, ‘Functional’ and ‘Targeted Advertising’. A detailed explanation of the types of Cookie and the purposes for which we use them is found within the Cookie Policy. However, if you are just looking for a summary, we use strictly necessary cookies to make our site work. We also like to set optional performance, functional and advertising cookies to help us improve the site and give you a bespoke experience so it works better for you.

  20. Contact Us
  21. You can contact us with any queries, complaints or requests to exercise your data protection rights using the details below:
    Telephone: +353(01) 4595158
    Post: 7 South Mall, Cork, Ireland

  22. Updates to this Privacy Policy
  23. Our Privacy Policy may change from time to time, and any changes to this Privacy Policy will be posted on the website and will be effective when posted. As your use of the TRANSLIT website is subject to your acceptance of this Privacy Policy, and any amendments thereto, please check back regularly.