Privacy Policy

1. Data Protection

1.1. With regard to the provisions of Law 15/1999 on the Protection of Personal Data (Spanish: Ley Orgánica de Protección de Datos de Carácter Personal, LOPD), Translafy.com acts as a means of transporting data, nor shall it transfer or sell the information obtained from the relationship with the "Client".

1.2. We will keep confidential at all times all information obtained as a result of the contract with regard to the Client and/or Company, except for information required to disclose by law, at the request of any regulatory body or competent bodies requesting it from us due to any force majeure reason.

1.3. The "Client" shall maintain the confidentiality of all information acquired as a result of this contract, except for that which it is obliged to disclose by law, by request of a regulator.

1.4. What rights do you have regarding your personal data?

1.4.1. Rights of access and amendment, you are entitled to know what personal information Translafy processes, and how it has been obtained. You are also entitled to request at any time to correct your personal information that is incomplete or incorrect.

1.4.2. Right to be forgotten, you can request that your data be deleted in specific circumstances, for example, if you have terminated the service, the personal data is no longer needed for the intended acquired reason, the data does not comply with the personal data law, the personal data must be erased in order to comply with a legal obligation in the European Union, etc.

1.4.3. Right to object, You are entitled to object to the processing of personal data that we base on our legitimate interest regarding your particular situation. If you object and the processing is based on a legitimate interest, we will no longer process your personal information unless we can demonstrate compelling and legitimate reasons for such processing that overrides your privacy interest. However, please note that even if you object to certain processing, Translafy may still continue such processing if it is based on a lawful basis, for example, to provide you with the Service (if you still wish to receive it) or to comply with legal obligations.

1.4.4. Right to restriction, You may request to restrict the processing of your personal data if incorrect, if you consider that the processing is unlawful, if Translafy bases its processing on a legitimate interest or if you believe that Translafy no longer needs the processing of personal data for the purposes set out in the "Description of data processing".

1.4.5. Right to withdraw consent, If you have given consent to Translafy to process personal data, you can always withdraw such consent for any future processing that relies on such consent.

1.4.6. Right to data portability, you are entitled to receive the personal data concerning you, which you have provided to us, and which we process on the basis of consent or to perform our agreement with you in a structured, commonly used and system-readable format. You may also request that we transmit such data directly to another controller where technically feasible.

2. Data processing description

2.1. The following data processing description describes the categories of personal data collected and processed by Translafy in relation to its users and the purposes of processing each category of data. In accordance with applicable data protection legislation, personal data can only be processed if there is a legally valid reason to support the processing. Translafy bases its processing on the following legal grounds as set out in the description:

2.1.1. Performance contract: the processing of personal data is necessary for Translafy to perform the Agreement with a User, for example, to enable the User to log in to his or her account, use the service and/or receive assistance.

2.1.2. Legitimate interest: The processing is based on a legitimate interest that Translafy has in processing, for example, to enable Translafy to send newsletters to users. A requirement is that such legitimate interest is not overridden by the interests, fundamental rights or freedoms of Users and Users are entitled to object.

2.1.3. Legal Obligation: Processing is necessary for Translafy to comply with the legal obligations applicable to Translafy, for example, financial information that needs to be stored for accounting purposes.

2.1.4. Time or retention criteria: Translafy specifies how long user data will be used for different purposes. Once the legal purpose is not maintained, all personal data will have been anonymized so a User can no longer be identified.

2.2. Categories of personal data. Translafy processes the following categories of personal data:

2.2.1. D1. Identification details: first name, surname, address, password Source: Directly from the user when registering or through Translafy

2.2.2. D2. Payment details: i.e. billing information and payment history Source: Directly from the User when registering and, as far as payment history is concerned, as payments are made.

2.2.3. D3. Digital information data, i.e. geographic location/IP address, device information (device type, device name, device ID), country code, ISP information, operating system version. Source: Collected based on the use of the service by the user and Translafy platforms.

2.2.4. D4. Usage information, i.e. information about shipments made and/or received, contact lists, user-created services and/or marketing tracking results. Source: Collected based on the user's use of the service.

2.2.5. D5. Customer service records, i.e. recordings of incoming customer service calls, email transcripts or chat correspondence Source: Correspondence with customer service is recorded.

2.2.6. D6. Cloud Service Responses: That is, user responses to services in which we ask a customer's intended users to participate, and responses may include personal information Source: directly from users who choose to participate in the services, from submissions made by a given customer.

2.3. Translafy processes the above categories of Personal Data for the following purposes:

2.4. P1.- Service Delivery Description: Allow Translafy to manage the user account and deliver the service to its users, as well as to enable the user to use our services, including the application of applicable terms and conditions. Legal basis: execution of a contract Categories of data involved: D1, D2, D3, D4, D5, D7 Retention time or criteria: up to 12 months after the end of the subscription for the Service or account creation (if the user never used the service).

2.5. P2.- Billing Description — To be able to bill the user for purchases made within the platform. Legal basis: execution of a contract Categories of data involved: D3 Retention time or criteria: from when the user makes the first payment to the user's request for withdrawal.

2.6. P3.- Customer service and/or technical service Description: To enable Translafy, and its resellers where applicable, to provide customer service to its users on demand, including troubleshooting. Legal basis: execution of a contract Categories of data involved: D1, D2, D3, D4, D5, D7 Retention time or criteria: up to 12 months after the end of the subscription for the Service or account creation (if the User never used the service).

2.7. P4.- Communication with users Description: To be able to send the relevant user information in connection with the subscription/account, for example, welcome email, service updates and the like. Legal basis: execution of a contract Categories of data involved: D2, D3, D4 Retention time or criteria: for the duration of the user's subscription to the Service.

2.8. P5.- Marketing Description: for profiling purposes in order to provide personalized marketing to Users and other target groups that may have similar preferences to current Users. This purpose includes sending newsletters to users. Legal basis: legitimate interest Categories of data involved: D1, D2, D3, D4, D5, D7 Retention time or criteria: for as long as permitted by applicable marketing legislation, but not more than 12 months after subscription termination or account creation (if the user never used the service).

2.9. P6.- Compliance with legal obligations Description: To enable Translafy to comply with the legal obligations applicable to Translafy, including the requirements of accounting regulations and responding to requests from authorities. Legal basis: legal obligation Categories of data involved: D1, D2, D3, D4, D5 Retention time or criteria: as long as the legal obligation exists, but in general up to 2 years.

2.10. P7.- Statistics and Analysis Description: to enable Translafy to improve the services offered to its Users, including improving the security of Translafy's systems. Legal basis: legitimate interest Categories of data involved: D2, D3, D4, D5, D7 Retention time or criteria: up to 12 months after the end of the subscription for the Service or account creation (if the User never purchased a subscription).

2.11. P8.- Fraud Prevention Description: To enable Translafy to prevent and defend Translafy against fraudulent claims by Users regarding payments. Legal basis: legitimate interest Categories of data involved: D3 Retention time or criteria: for the duration of the User's subscription and up to 5 years after the end of the Subscription.

2.12. P9.- Customer Service Training Description: Call recordings and other 6 correspondence with customer service are analyzed to improve the quality of customer service provided to Users and others contacting Translafy customer service. Legal basis: legitimate interest Categories of data involved: D6 Retention Time or Criteria: 3 months.