Last updated 04/06/2018
Website, Marketing, Email Communications and Online Channels
We at Topp Language Solutions (“Topp Language Solutions” or “we” or “us” or “our”) understand that privacy is important. Our policy has been created to assist you in understanding how we use any personal data via our website, our online booking system, through our online training courses and other related services.
Please read this policy to learn more about the ways we use your information. Any changes to our policy you will be notified, the process for this can be found in the “revision of changes” section of this policy.
By using our services, you consent to our collection, use and disclosure of your information as described in this policy.
Definitions and interpretation
Data collectively all information that you submit to Topp Language Solutions ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998.
1.1 Topp Language Solutions ltd, we or us Topp Language Solutions ltd, a company incorporated in England and Wales with registered number 08473338 Whose registered office is at Topp Language Solutions ltd, 7 St. Petersgate, Stockport, United Kingdom, SK1 1EB
1.2 User or You any third party that accesses the Website and is not either (i) employed by Topp Language Solutions ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Topp Language Solutions ltd and accessing the Website in connection with the provision of such services; and Website the website that you are currently using, http://topplanguagesolutions.co.uk, https://topplanguagesolutions.interpreterintelligence.com and any sub-domains of this site unless expressly excluded buy their own terms and conditions.
We may collect the following Data, which includes personal Data, from you,
2.2 Date of Birth
2.4 Job Title
2.6 Contact Information such as email addresses and telephone numbers
2.7 Demographic information such as address, post code, preferences and interests
2.8 Financial information such as credit/debit card numbers
Our use of Data
3. For purposes of General Data Protection Regulation (Regulation (EU) 2016/679, Topp Language Solutions ltd is the “data controller”
Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This our affiliates and/or other companies within our group.
3.1 All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the Security clause.
3.2 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
3.2.1 Internal record keeping
3.2.2 Improvement of our products/services
3.2.3 Contact for market research purposes which may be done using email, telephone or post. Such information may be used to customise or update the Website
Third party websites and services
4 Topp Language Solutions ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website. Any working on our behalf subject to our Terms of Service.
Links to other websites
Changes of business ownership and control
6.1 We may also disclose Data to a prospective purchaser of our business or any part of it.
6.2 In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Controlling use of your Data
7 Where ever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
7.1.1 Use of Data for direct marketing purposes; and
7.1.2 Sharing Data with third parties
Functionality of the Website
8. To use all features and functions available on the Website, you may be required to submit certain Data.
Accessing your own Data
9. You have the right to ask for a copy of any of your personal Data help by Topp Language Solutions ltd (where such Data is held) which is free, therefore if more copies are required a small fee of £10 is required. To request your data please visit http://topplanguagesolutions.co.uk/privacy-tools/ and complete the “Download your Data” section.
10. Data security is of great importance to Topp Language Solutions ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
10.1 If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
10.2 We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
11.2 Unless otherwise agreed, no delay, act or omission by a party in the exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
11.3 This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Use of Testimonials
13. We may select and post testimonials on our Services, which may contain personal information such as your name, company or profession. We will obtain consent before posting any testimonial with your name. If you post such content to our site or social media it will be available to other users of our Services. You posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove or delete your testimonial or name from our Services, you may contact Topp Language Solutions ltd using the information in the “how to contact us” section of this Policy.
Use of widgets
15. Out sites may include social media features, such as Facebook or Twitter buttons and similar widgets. To the extent we use these Features, they may collect your IP address, which page you are visiting on our site, and may se a cookie to enable the feature to function properly. Social media features and widgets are either hosted b a third party or directly by our site. Your interactions with these features are governed by the privacy statement of the company providing the feature or widget.
Disclosures Made by You within Interactive Areas of a Site
16. Any personally identifiable information you submit when using a blog, commenting or is a discussion forum can be read, collected, or used by others of these areas, and could be used to send you unsolicited messaged, and could be potentially searchable through search engines. We are not responsible for the potential misuse by third parties of any personally identifiable information that you choose to submit in these areas.
17. We may communicate, from time to time, with a customer through email using their personal contact information that we have on file to inform the customer of new products, news or information about out Services.
17.1 There are occasions where we retain email communication for longer than 6 years. This is to help us understand our clients’ needs and provide a World Class Customer Experience.
17.2 From time to time, we may use your email address for online marketing of products and services that we believe are beneficial to you.
18. Topp Language Solutions retain paper-based and electronic files of financial data for 6 years as required by HRMC.
How we use Personal Info
19. Personal information may be collected from you in various was, for example:
19.1.1 When you conduct activities on our site, by purchasing a product or service (we record what you purchased etc.) We may collect your name and contact details, details of your subscription to our services or online training, and other information gathered by Facebook or Twitter and transferred to us, including your address.
19.1.2 When you register and voluntarily provide information in response to questionnaires or register for newsletters/correspondence from us.
20. Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us using the details provided or using the Privacy Tools provided on my website at http://topplanguagesolutions.co.uk/privacy-tools/ .
21. There will not usually be a charge for handling a request to exercise your rights.
22. If we cannot comply with your request to exercise your rights we will usually tell you why.
23. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
24. If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request then we do not have to respond. Alternatively, we can charge for responding.
Your rights include:
The right to access your personal information
25. You are usually entitled to a copy of the personal information we hold about you and details about how we use it. To request this please use the privacy tools located on my website at http://topplanguagesolutions.co.uk/privacy-policy/. Your data can be requested under the heading Download Your Data .
26. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible.
27. Please note that in some cases I may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.
28. You are entitled to the following under data protection law.
1. Under Article 15(1) of the GDPR we must usually confirm whether e have personal information about you. If we do hold personal information about you we usually need to explain to you:
i. The purposes for which we use your personal information
ii. The types of personal information we hold about you
iii. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
iv. If your personal information leaves the EU, how we will make sure that it is protected
v. Where possible, the length of time we expect to hold your personal information. If that is not possible, the criteria we use to determine how long we hold your information for
vi. If the personal data we hold about you was not provided by you, details of the source of the information
vii. Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
viii. Your right to ask us to amend or delete your personal information
ix. Your right to ask us to restrict how your personal information is used or to object to our use of your personal information
x. Your right to complain to the Information Commissioner’s Office
2. We also need to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.
The right to rectification
29. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
The right to erasure (also known as the right to be forgotten)
30. I may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can always be found at http://topplanguagesolutions.co.uk/privacy-tools/. In the event that there are any material changes to the manner in which your personal information is to be used then we will provide you with an updated copy of this Privacy Notice.
31. In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.
31.1 To exercise your right to erasure please use the Privacy Tools found on my website at http://topplanguagesolutions.co.uk/privacy-tools/ – The option to invoke this right can be found under Delete my User & Data
The right to restriction of processing
32. In some circumstances, we must “pause” our use of your personal data if you ask us to do so, although we do not have to comply with all requests to restrict my use of your personal information. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
The right to data portability
33. In some circumstances, we must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format.
33.1 To request this please use the privacy tools located on our website at http://topplanguagesolutions.co.uk/privacy-tools/. Your data can be requested under the heading Download Your Data.
The right to object to marketing
34. You can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting us using our contact form.
The right not to be subject to automatic decisions (i.e. decisions that are made about you by computer alone)
35. You have a right to not be subject to automatic decisions (i.e. decisions that are made about you by computer alone) that have a legal or other significant effect on you.
36. Please see section 80 for detail about when we may make automatic decisions about you.
37. If you have been subject to an automated decision and do not agree with the outcome, you can challenge the decision.
The right to withdraw consent
38. In some cases we may need your consent in order for our use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting us using our contact form.
The right to complain to the Information Commissioner’s Office
39. You can complain to the Information Commissioner’s Office if you are unhappy with the way that I have dealt with a request from you to exercise any of these rights, or if you think I have not complied with our legal obligations.
40. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
41. Making a complaint will not affect any other legal rights or remedies that you have.