Privacy Policy

Who we are

This website is run by The Translation Department Limited, trading as Transferendum. We are registered in Ireland under company number 695147. Our registered office is Unit C, First Floor, 34 Usher's Quay, Dublin 8, D08 XA07, Ireland. Our postal address is 1st Floor, 34 Usher's Quay, Dublin 8, D08 XA07, Ireland.

We provide translation, localisation and certified translation services. We work from a scan or a clear photograph, and we never take the original document. Standard turnaround is 3 working days. An urgent service starts at 24 hours.

Our data protection contact is Ronan Power, Managing Director. Write to privacy@transferendum.eu, or to the postal address above. Our telephone number is +353 1 963 1720.

We hold two roles in data protection law. For the personal data inside the documents a client sends us for translation, the client is the controller and we are the processor. For our own customers, suppliers, linguists and website visitors, we are the controller. The data protection page sets out both roles in full.

What we collect

This section describes the personal data we hold, by the situation in which we receive it.

• Website enquiries. The contact form asks for your name, your email address, your phone number, your message and any file you attach. The website records the visit, including the IP address, the browser user agent and the pages viewed. We store contact form submissions in our customer relationship management system.
• Customers and suppliers. We hold contact details, including name, organisation, address, email address and phone number. We hold project details, correspondence, invoiced amounts and payment records. We hold tax and accounting details where the law requires them.
• Documents you send for translation. Those documents can contain personal data about you, and about other people named in them.
• Linguists and applicants. If you apply to work with us, we hold your CV and the details in it, together with the documents that evidence your identity, your qualifications and your legal right to work. When you work with us, we hold the details we need to assign work and to pay you.
• Website chat. If you start a conversation in the website chat, we store the conversation.

Why we process it and the legal basis

We process personal data for the purposes below. Each purpose rests on a legal basis under Article 6 of the General Data Protection Regulation.

• Answering an enquiry and preparing a quotation. Legal basis: Article 6(1)(f), our legitimate interest in answering the people who contact us.
• Delivering translation, localisation and certification work, and invoicing it. Legal basis: Article 6(1)(b), performance of the contract with you.
• Keeping tax, accounting and other statutory records. Legal basis: Article 6(1)(c), compliance with a legal obligation.
• Website security, bot prevention, fraud prevention and service improvement. Legal basis: Article 6(1)(f), our legitimate interest in running a secure and working website.
• Assessing applicants and engaging linguists. Legal basis: Article 6(1)(f), our legitimate interest in recruiting the people who do the work.
• Optional marketing email. Legal basis: Article 6(1)(a), your consent. We ask for that consent separately, and you can withdraw it at any time.

We do not rely on consent to carry out translation work. We do not send marketing email today. We do not sell personal data, and we do not pass it to anyone for their own marketing. We process the personal data we hold only for the purposes above. We do not build a profile of you, and we do not make automated decisions about you.

Documents and special category data

Documents sent for translation often contain special category data within the meaning of Article 9 of the Regulation. Medical reports, immigration files, court documents, Garda documents, birth records, adoption records and other official records are common examples in our work.

Where you instruct us to translate your own documents, you are the controller of that personal data and you establish the Article 9 condition for processing it. We process the documents on your documented instructions, and only to produce the translation you asked for.

We protect that material in these ways. Access is limited to the people who work on the job, on a need to know basis. Every employee and every linguist signs a written confidentiality and data protection undertaking. We do not reuse your content for any other purpose. We delete the material as the retention schedule below provides.

Translation work is carried out by people. A qualified linguist translates or post-edits the text, and a second qualified linguist checks it before delivery. We use the material only for the job you asked for. We do not use it for profiling or analysis, and no recipient may use it for a purpose of their own.

Who receives your data

We share personal data with the recipients below. Each one receives only what the service needs.

• Freelance and agency linguists. They are our sub-processors and contractors. We engage each of them under a written contract that carries confidentiality and data protection terms. A linguist receives only the material needed for the job assigned, and works on it under our instructions.
• Our translation management system. The system holds the job file while the work is in progress.
• Microsoft 365 and SharePoint. They carry our email and our document storage.
• Odoo. It runs our enterprise resource planning and our customer relationship management, and it runs this website.
• Cloudflare Turnstile. It carries out the anti-bot check on the contact form.
• Our payment providers. They process card and bank payments for our services.
• Our hosting provider. It hosts this website and the systems behind it.
• Professional advisers, auditors and insurers, where the law requires a disclosure or where a claim requires it.
• Public bodies, including the Revenue Commissioners, where the law requires a disclosure.

Our Article 28 data processing agreement states how we appoint a sub-processor on a client's work, and how we tell the client about a change. A copy of that agreement is available on request.

Transfers outside the EEA

Some of the suppliers we use hold infrastructure outside the European Economic Area. Microsoft, Cloudflare and Odoo all operate global infrastructure, so a transfer can occur when their systems store or route our data.

Where personal data leaves the EEA, we rely on a safeguard that the law provides. Where the European Commission has adopted an adequacy decision for the destination, that decision covers the transfer. That includes the EU to US Data Privacy Framework where the supplier holds the certification. In other cases we use the Standard Contractual Clauses of the European Commission, and we record a transfer risk assessment for the transfer.

We do not rely on consent for a transfer outside the EEA. A transfer rests on one of the safeguards above, and we keep the evidence behind it.

How long we keep it

We keep personal data for the periods below. The same schedule appears as a table on the data protection page.

• Hard copy documents, including working copies and notebooks. Destroyed by shredding, or returned to you, within 4 weeks of job completion.
• Electronic working files. Destroyed within 24 weeks of job completion.
• Certified translated documents. Purged from our archives and backups within 180 days of job completion. We keep a reference to the certification of the job.
• Translation memory entries. Held in a form that does not allow the reconstruction of personal data.
• Job accounts. Reconciled within 6 months of job completion.
• Transactional and accounting records, including invoices. Kept for 6 years under tax law.

The periods start at the completion of the job. We delete other records, including enquiries that do not lead to a job, when we no longer have a business reason to keep them.

Your rights

You have the right to:

• ask for a copy of the personal data we hold about you;
• ask us to correct data that is inaccurate or incomplete;
• ask us to delete data, or to restrict how we use it;
• object to how we use your data;
• ask us to move your data to another provider;
• withdraw consent, where consent is the basis for the processing.

Send your request to privacy@transferendum.eu, or to our postal address. We answer within one month. We may ask you to prove your identity before we act on a request.

Where the personal data arrived in a client's job and you did not instruct us, that client is the controller of the data. Write to the client, and tell us as well. We pass the request to the client and give them the help they need to answer it.

How to complain

Tell us first, at privacy@transferendum.eu. We look into the matter and reply to you.

You have the right to complain to the Data Protection Commission. The address is Canal House, Station Road, Portarlington, R32 AP23, Co. Laois. The telephone numbers are 0761 104800 and 1890 252231. The email address is info@dataprotection.ie.

How to contact us

The Translation Department Limited, trading as Transferendum. 1st Floor, 34 Usher's Quay, Dublin 8, D08 XA07, Ireland. Telephone: +353 1 963 1720. Email: info@transferendum.eu. Data protection contact: Ronan Power, Managing Director, privacy@transferendum.eu.

This notice can change. We publish the date of the last update at the top of the page.