Privacy and Cookies Policy

Conversis understands that your privacy is important to you and you care about the use of your personal data. We respect and value the privacy of our customers, employees, suppliers and all individuals whose data we process; this privacy statement explains what personal data or information we collect from you at various points in our process, and from people who visit our website, and how we use it. We would encourage you to read the information below.

Who are we?

Oxford Conversis Limited, trading as Conversis, is a registered company (04580340) and our registered office address is: Office 10, Building B, Kirtlington Business Centre, Kirtlington, Oxfordshire, OX5 3JA. Oxford Conversis Limited is a registered data controller (ICO registration number ZB349712).

What is Personal Data?

“Personal data” is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data means, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What personal data or information do we collect?

We may collect personal data about customers, prospective customers, job applicants, our current and former employees, our linguists and suppliers. In addition, we may process personal data contained within the documents we are translating. The personal information we collect may include your name, address, email address, IP address, and information regarding what pages you access on this website and when. We provide greater detail about the data collected for each group of individuals below.

How do we collect data or information from you?

We collect personal information about you when you:

• Make an enquiry via our website or via the telephone
• Purchase translation services from us
• Use our website
• Enquire about a job opportunity
• Work for or with the business
• Exchange business cards with a member of the business
• How is your information used?

We collect your personal data or information to operate the business effectively and provide you with a high-quality service. We may use your information:

• To deliver translation services to you
• To answer enquiries that you make prior to any agreement or contract
• To keep you informed about our services and our insight into industry trends, if you have opted-in to receive these communications
• To monitor the quality of translation services, and ensure regulatory requirements are met (e.g. audit)
• To process a job application
• To fulfil our obligations as a responsible employer
• To provide benefits to you as an employee
• To manage our contracts with you as our linguists
• To maintain the security of our office and IT infrastructure
• To invoice you, and to track payments you make or payments made to you

We believe that all these purposes are justified on the basis of our legitimate interests in running and promoting the business, our contractual requirements to deliver the agreed products and services to you, and our legal obligations, both as a business and responsible employer. If you would like to know more, please read below:

Customers

As a customer, we will hold the following information about you:

• Name and business contact information
• Financial information
• Demographic information such as postcode, preferences and interests
• Information and documents relating to the products and services we are providing, including communications with you
• Billing and payment information.

We store your information in our Translation Management Software, which is located on our own secure servers in the UK, and on our CAT Software, which is located on our own secure servers in the UK. Our CRM System, which we use at the early stage of our relationship with you as a prospect, and our Financial Management Software have servers in the USA, which means your data will be transferred outside of the UK and EEA. Further details about international transfers are available later in the policy. We may also hold paper copies of your information stored at our archiving facility. Communications with you will be stored in our email system and Office 365 Suite of products.

We will retain your details for the duration of our relationship with you, and for a minimum period of 6 years after the end of the contract. We currently retain key project contact information indefinitely to support our audit requirements. Anonymization is available on request. We will retain financial records for 6 years, following the end of the current financial year.

In some circumstances, you may share the personal details of individuals within the original documents you provide for us to translate. Where this is expected (e.g. job titles of people to contact within reports or letters), we will process the personal data on your behalf and not use it for any other purposes. If it is unexpected and we believe the information should have been redacted (e.g. patient details or identifiers in medical reports), we will take steps to redact the information in the original document and in the translation provided back to you. We will also notify you of the error as soon as possible.

Prospective Customers

As a prospective client, we may hold the following information about you:

• Name and business contact information
• Information and documents relating to the services you require, including communications with you

We store your information in our CRM system, which has servers in the USA. This means your data will be transferred outside of the UK and EEA. Further details about international transfers are available later in the policy. We may also hold paper copies of your information stored at our archiving facility. Communications with you will be stored in our email system and Office 365 Suite of products.

Where our relationship with you does not progress beyond the enquiry or proposal stage, we will retain your details for a maximum period of 3 years since the last meaningful communication we had with you.

Job Applicants

When you apply for a job with us, we may hold the following information about you:

• Name, date of birth, and contact information
• Information relating to your qualifications and experience
• Identification and Right to Work Documents, such as passport, visa and settled status confirmations
• References where we take them up
• Information and documents relating to the review, interview and selection process, including communications with you.

We store your information on our Office 365 Suite of products and, once we make an offer to you, on our HR system which uses secure servers in the UK. We will also store communications with you relating to the interview process in our email system, which we use Office 365 to manage.

We will retain your personal data relating to the review, interview and selection process for a period of 6 months after the interview date.

Current and Former Employees

When you work for us, we may hold the following information about you:

• Name, date of birth, and contact information
• National insurance number and Unique Tax Reference (UTR)
• Information relating to your qualifications and experience
• Demographic information such as postcode
• Information and documents relating to your performance and supervision as an employee of the business, including communications with you
• Your photograph, including your passport
• Financial information, such as bank details, pension scheme and salary details
• Information about your next of kin
• Health information, for example, allergies or information needed to make reasonable adjustments if required.

We store your information on our HR system to help us manage performance, sickness, absence, and accidents in the workplace and to support your development and supervision. We will also store communications with you using our suite of Office 365 products. You are able to access your payslip via an online portal, which uses secure servers in the UK.

We use WhatsApp to communicate updates as required to the Conversis Team, for example, ‘Do not go to the office’ in case of emergency or office communications being disrupted.

We will retain your personal data for the duration of your employment and for a period of 7 years after you leave Conversis. Beyond this point, we only retain minimal information about you to confirm the period of time you were employed by the business for reference purposes. We share your information with HMRC and our chosen pension/benefits providers. Information about the Directors of the business will be held indefinitely for historical purposes.

Linguists

As a linguist available to contract for Conversis, we may hold the following information about you:

• Name and business contact information
• Financial information
• Information relating to your business activities and language skills
• Qualifications and experience
• Feedback on your previous performance in providing translation services on our behalf
• Demographic information such as postcode, preferences and interests
• Your availability to work for us, which may include high-level notes about sickness or absence
• Information and documents relating to the translation services we are providing to our customers with you, including communications with you.

We store your information in our Translation Management Software, which is located on our own secure servers in the UK, and on our CAT Software, which is located on our own secure servers in the UK. Our Financial Management Software has servers in the USA, which means your data will be transferred outside of the UK and EEA. Further details about international transfers are available later in the policy. Communications with you will be stored in our email system.

If you do not progress past the Initial Status Test, which all linguists undertake to assess their translation skills, we will retain your details on file to avoid duplicate or repeat applications. If you are successful in passing the test, we will retain your details on our system with related availability until you notify us that you no longer wish to be considered for translation work. Your details may remain on the project management system for a significant period of time after project completion in order to support our regulatory obligations to make information available for audit purposes. We retain financial information for 6 years, after the end of the current financial year.

Suppliers

When you work with the business as a supplier, we may hold the following information about you:

• Name and business contact information
• Information relating to your qualifications and experience
• Demographic information such as postcode
• Information relating to your business activities
• Information and documents relating to the services or products you offer, including our communications with you
• Financial information

We store your information on our MS Office Suite of products and on our own secure servers hosted in the UK. Our Financial Management Software has servers in the USA, which means your data will be transferred outside of the UK and EEA. Further details about international transfers are available later in the policy. Communications with you will be stored in our email system.

We will retain your information for the duration of our relationship with you and for 2 years after the last purchase we made with you. We retain financial information for 6 years, after the end of the current financial year.

Who has access to your information?

We limit access to your personal data to those employees, contractors, and third-party processors (see below) who have a legitimate need to know and ensure that they are aware of their duty of confidentiality.

We do not sell or rent your personal data or information to any third party or share your information with third parties for their own marketing purposes.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may pass your information on to third-party service providers, agents, or subcontractors for the purposes of completing a task or providing services to you on our behalf (e.g. managing email marketing campaigns). However, we disclose only the personal information necessary to deliver that service and have a contract in place that requires them to keep your information secure and not to use it for other purposes.

Third-party service providers who act as data processors on our behalf:

Service Provider – Accounting Software (data processor)
Activity Carried Out – CRM Software
Sector – Financial
Location – UK

Service Provider – Payroll Provider (data processor)
Activity Carried Out – Provision of accounting software
Sector – Information Technology (software)
Location – USA

Service Provider – CRM Software (data processor)
Activity Carried Out – Provision of software used to manage communications with leads and prospective customers.
Sector – Information Technology
Location – USA

Service Provider – IT Support Provider
Activity Carried Out – Manage IT and Security
Sector –  Information Technology
Location – UK

Service Provider – Translation Management Software (data processor)
Activity Carried Out – Provision of software to manage and record translations
Sector –  Translation
Location – UK

Service Provider – HR Software (data processor)
Activity Carried Out – Provision of HR software
Sector –  HR
Location – UK

Service Provider – Archive Storage (data processor)
Activity Carried Out – Storage of paper files in archive facilities
Sector –  Storage
Location – UK

If any of your personal data are shared with a third party, as described above, we will take steps to ensure that your personal data are handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

Transfers outside of the UK and European Economic Area

Our translation services cover a variety of languages and we work with native speakers located all over the world to provide the best service to you. As such, we may store or transfer some or all of your personal data to countries that are not part of the UK or European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data are treated just as safely and securely as they would be within the UK and under our Data Protection Legislation as follows:

• We share your data with external third parties, as detailed in the table above, that are based outside of the UK & EEA. The following safeguards are applied to such transfers:
  • We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the Information Commissioner’s Office
  • We use specific contracts with external third parties that are approved by the Information Commissioner’s Office and the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
  • Where we transfer your data to a third party based in the US additional steps have been taken to ensure your personal data will be treated as securely and safely as it would be in the UK and under the GDPR. We have signed Data Processing Agreements with our data processors based on model contract clauses provided by the Information Commissioner’s Office and European Commission (also known as ‘standard contract clauses’), which impose suitable data protection standards on a contractual basis.

• We share your data with our linguists based outside of the UK & EEA. In addition to the above, we ask them to adhere to our data protection policies as part of their work with us.
  • Please contact us using the contact details provided below for further information about the particular data protection mechanisms used when transferring your personal data to a third country.

What are my rights?

Under Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details provided at the end of this policy.
• The right to access the personal data we hold about you. The section “How Can I Access My Personal Data?” will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us are inaccurate or incomplete. Please contact us using the contact details provided at the end of this policy.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold, in certain circumstances. Please contact us using the contact details provided at the end of this policy to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data are processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the contact details provided at the end of this policy.

It is important that your personal data are kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed for as long as we have those data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first using the contact details provided at the end of this policy

We ask for your consent to send you direct marketing information and will always provide you with the opportunity to amend your preferences or to opt-out of receiving future marketing communications from us.

How you can update your information

The accuracy of your information is important to us. If you change your contact details or if you want to update any of the information we hold on you, please email us at: charlotte.terry@conversis.com or by post at: Office 10, Building B, Kirtlington Business Centre, Kirtlington, Oxfordshire, OX5 3JA.

How you can access your personal information

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests can be made in writing, either via email or via the postal addresses shown below, or verbally, either in person or on the phone.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required, up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

You also have the right to lodge a complaint about our processing of your personal data with the UK’s Information Commissioner’s Office.

Keeping your data secure

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• Limiting access to your personal data to those employees, contractors and third-party processors with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
• Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
• Adhering to our policies and processes including, physical security, backup, encryption, access control and password protocols.

Contacting us via email

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government standards. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

California Residents

Conversis operate in the USA and this privacy policy covers the key aspects of the requirements of the California Consumer Privacy Act (CCPA) and the California Online Privacy Protection Act (CalOPPA). We uphold all your rights in the same way we do UK and EEA Citizens’ personal data.

Within the definition of ‘Sale of Data,’ as set out in the California Consumer Privacy Act, the use of cookies for analytical and marketing purposes is the only aspect of our processing activities that fall under this definition. Otherwise, we do not sell your data to third parties. We provide a cookie management tool that gives you the option to accept or decline all non-essential cookies (including analytical cookies), which means we will not sell your date if you do not accept these cookies. More information is available in the cookie section below. If you wish to have guidance on how to opt-out of previously accepted cookies on this website, you can contact the Data Protection Officer at the details below for more information.

Do Not Track

We do not respond to ‘Do Not Track’ signals in web browsers. We give you the option to accept or decline non-essential cookies, including analytics and marketing cookies, when you arrive at our website using the cookie management tool.

Cookie Information for Visitors to our Website

What are cookies?

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies provide information about individuals’ usage of the website, which may identify you as the same individual even if we do not know your name, we can identify your location, IP address, and device information. As such, we make sure you have a choice about the cookies that are placed on your device for our statistical purposes by Google Analytics, which helps us to understand more about the ways in which people use our website. We would appreciate it if you opt-in to accept these cookies when the website asks you, as it will help us to improve it over time.

What Cookies do we use?

We have provided a cookie declaration to explain what cookies use here https://www.conversis.com/cookie-declaration

Links to other websites

Our website may contain links to other websites run by other organizations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

How do I contact you?

To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details for the attention of:

Data Protection Lead: Charlotte Terry
Email address: charlotte.terry@conversis.com
Postal address: Office 10, Building B, Kirtlington Business Centre, Kirtlington, Oxfordshire, OX5 3JA.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 17/11/2022.