Privacy Notice

This Privacy Notice (“Privacy Notice”) applies to individuals who use our website at transalis.com (the “Site”) and any of the products and services that we offer, including from the Site.

We respect the privacy of every person who visits or registers with or submits personal information through our Site and who uses the products and services that we offer, including from the Site, and we are committed to ensuring a safe online experience.

1. Purpose Of This Privacy Notice

This Privacy Notice explains our approach to any personal information that we might collect from you or which we have obtained about you from a third-party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.

This Privacy Notice informs you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our products and services. Please take a moment to read and understand it. It should be read in conjunction with our Terms and Conditions.

This Privacy Notice only applies to the use of your personal information obtained by us; it does not apply to personal information collected during your communications with third parties or your use of their products or services.

2. About Us

The Site and our products and services are made available by Transalis Limited (“Transalis”, “we”, “us”, “our”). Transalis is the data controller responsible for your personal information. For more information.

Transalis is a private limited company registered in England under registration number 04581648 with its registered office located at C/O Browne Jacobson LLP, 6 Bevis Marks, London EC3A 7BA.

Transalis is registered as a data controller with the UK Information Commissioner’s Office under registration number ZA20480.

3. How To Contact Us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please:

• Send us an email at: dpo@transalis.com
• Call us on: 0845 123 3476
• Write to us at: DPO, Transalis Ltd, Portsmouth Technopole, Portsmouth, PO2 8FA, United Kingdom

4. Personal Information We Collect And How We Use It

We may collect and process personal information from you in the following circumstances:

Site visitors: If you browse our Site, contact us with an enquiry through our Site, apply for an account on our Site or use any services available on our Site, we may collect and process your personal information in connection with your interaction with us and our Site.
Customers: If you purchase our products or services on your own behalf, we may collect and process your personal information in connection with your purchase and our wider relationship with you.

Suppliers (including subcontractors): If you supply products or services to us on your own behalf, we may collect and process your personal information in connection with our receipt of products and services from you and, where relevant, our provision of products and services to our customers.

Individuals who work for our customers and suppliers: Corporate organisations are not data subjects, although any individuals who work for them are. If you work for or otherwise represent one of our corporate customers or suppliers and you are engaging with us on behalf of that organisation, whether through our Site or otherwise, we may collect and process your personal information in connection with our receipt or provision of products and services and our wider relationship with your organisation.

Job applicants: If you apply for a job with us, we may collect and process your personal information in connection with your application.

Our primary reasons for collecting personal information from you is to: (i) provide our products and services to you and/or any organisation you represent; (ii) verify your identity (where applicable); (iii) help us improve our Site and our products and services and develop and market new products and services; (iv) carry out requests made by you on our Site; (v) investigate or settle enquiries or disputes; (vi) comply with applicable law, court order, other judicial process and the requirements of regulators; (vii) enforce our agreements with you; (viii) protect the rights, property and safety of us or third parties, including our other customers and users of the Site; (ix) provide support for the provision of our products and services; (x) carry out recruitment activities; and (xi) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

• Fulfilment of our products and services.

  We collect and maintain personal information that you voluntarily submit to us during your use of our Site and the products and services we offer on our Site and when you request products and services from us, whether for yourself or on behalf of any organisation you represent. We may also collect personal information about you when someone else within the organisation you represent voluntarily submits information to us via our Site or otherwise, for example if you are nominated as a point of contact or authorised signatory.

  Account registration and use: If you apply for an account with us (whether on your own behalf or on behalf of the organisation you represent), we will collect and process the following personal information in order to process your application:

  • name and title;
  • job role;
  • company name and address;
  • company website URL;
  • contact information (including email address, telephone number and fax number)
  • contact details for your primary sales contact and primary technical contact (including name, title, email address and telephone number);
  • information about your organisation, including the nature of the business, the territories covered, the number and type of employees and information about existing solutions providers; and
  • any personal information you volunteer on the registration form.

  Once you have submitted your application, we will process your email address and password to identify you when you log into secure areas of our Site. We will use your account information so that we can administer your account with us and contact you about your account. Your access to and use of our Site, including any secure areas such as your account area, is subject to our Terms and Conditions.

  Provision of products and services: We use your name, contact information (including email address and telephone number) and payment details you have provided so that we can fulfil the supply of products and services you have requested from us, including from our Site, and to process any returns and/or refunds. Certain products and services we offer, through the Site or otherwise, are also subject to specific terms and conditions which apply to the purchase and use of such products and services.

  Who do we share your personal information with for this purpose?

  Please note there may be circumstances where we need to share personal information with other third parties in order to provide the products and services as effectively as we can.

  Some of our third-party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

  What is our legal basis?

  It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (or the organisation you represent) or it is in our legitimate interest or a third-party’s legitimate interest to use personal information in such a way to ensure that we provide the products and services you have requested in an effective and efficient way.

• General customer services and enquiries.

  Our Site features a “Contact Us” form to allow you to submit enquiries about our Site and our products and services online. When you make an enquiry using the “Contact Us” form, we will collect and process your name, email address and any personal information you volunteer which is relevant to your enquiry.

  We also have a “Partner Enquiry Form”. When you make an enquiry using this form, we will collect and process your name, email address, company name, company website URL and any personal information you volunteer which is relevant to your enquiry.

  We also accept enquiries by email, telephone and post. When you submit an enquiry in this way, the following personal information may be collected: name, company name, your department, your contact information (including email address and telephone number), post code and any personal information you volunteer that is relevant to the enquiry.

  We use this information to enable us to manage and respond to your enquiries and to provide any information you have requested.

  Who do we share your personal information with for this purpose?

  We do not share your personal information for this purpose.

  What is our legal basis?

  It is in our legitimate interest to use your personal information in such a way to ensure that we provide a good standard of customer service to you.

• Your feedback about our products and services.

  From time to time, we may invite you to provide feedback about us or our products and services in the form of online or postal surveys. We will collect your name and contact details (including email address, postal address and telephone number, as applicable) and any other personal information you choose to volunteer in your feedback.

  We use this information to help us improve the quality of service provided by our personnel. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

  Who do we share your personal information with for this purpose?

  We do not share your personal information for this purpose.

  What is our legal basis?

  It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.

• Insight and analysis.

  We analyse your contact details with other personal information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services.

  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site; and
  • information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.

  Our web pages may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web page [or opened an email] and collect other types of aggregated information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and/or the relevant Tag.

  In some of our email messages, we may use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

  Please see our Cookie Policy for further information.

  This information is used to create insights about our visitors’ browsing habits on our Site. Where we have your consent to do so, we will also use your location data for insight and analysis purposes.

  By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our products and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors and clients like to see.

  We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences.

  We may also use this information for marketing purposes (see the “Marketing Activities” section below for further details).

  Who do we share your personal information with for these purposes?

  We share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

  Some of our third-party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

  What is our legal basis?

  Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

  Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide good quality products and services to you (or the organisation you represent) and our other customers.

  We will only use your location data for insight and analysis purposes where we have your consent to do so.

• Marketing activities.

  We carry out the following marketing activities using your personal information:

  • Postal marketing. We use your name and address to send you (or the organisation you represent) marketing communications by post. Such communications will include information about the products, services, offers and promotions we offer from time to time.Our postal marketing will include personalised and non-personalised postal marketing. Personalised marketing is marketing which has been specifically tailored to you (or the organisation you represent). For example, our personalised postal marketing will feature products, services, offers and/or promotions that we think are most likely to appeal to you (or the organisation you represent). Non-personalised marketing is marketing about our products, services, offers and/or promotions generally and is not tailored to any particular individual.Where we are sending you personalised postal marketing, we also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services in order to decide what sort of personalised marketing communications to send. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected.

    Who do we share your personal information with for these purposes?
    We share your personal information with third-party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

    What is our legal basis?
    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

    Where your personal information is not in an anonymous form, which will be the case with your postal address, it is in our legitimate interest to use your personal information for marketing purposes.

    We will only use your location data where we have your consent to do so.

  • Email marketing. We use your name and email address to send you (or the organisation you represent) marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful right to do so. Such communications will include information about the products, services, events, offers and promotions we offer from time to time. Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you (or the organisation you represent). For example, our personalised email marketing will feature our products, services, offers and/or promotions that we think are most likely to appeal to you (or the organisation you represent). Non-personalised marketing is marketing about our products, services, offers and/or promotions generally and is not tailored to any particular individual. Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services in order to decide what sort of personalised marketing communications to send. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected.

    Who do we share your personal information with for these purposes?

    We share your personal information with third-party email marketing providers who assist us in delivering our email marketing campaigns.

    [Some of our third-party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.]

    What is our legal basis?

    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

    Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

    We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to do so.

    We will only use your location data where we have your consent to do so.

• Recruitment.

  We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf.

  We may process any personal information about you that you volunteer when you apply for a job with us. Such information may include your name and contact information (including your email address, postal address and telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae or which is relevant to your potential recruitment. Such information may also include special categories of personal information and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

  We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

  Who do we share your personal information with for these purposes?

  Where applicable, we will share your personal information with external recruiters and third-party providers that undertake background checks on our behalf.

  What is our legal basis?

  Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions.

  We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

• Receipt of services from suppliers.

  If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we may collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide products and services to our customers.

  The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.

  Who do we share your personal information with for this purpose?

  We may share your information with other companies within our group of companies and with other suppliers where relevant to the provision of our products and services and with our payment providers in order to pay your invoices.

  What is our legal basis?

  It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship and are able to provide our products and services to our customers in an effective way.

• Business administration and legal compliance.

  We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • to protect the rights of third parties; and
  • in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

  Who do we share your personal information with for these purposes?

  We will share your personal information with professional services firms such as lawyers and accountants who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we become involved in.

  We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

  Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

  We may share personal information with other organisations within our group of companies where necessary for administrative purposes or where those organisations assist us in the provision of our products and services.

  What is our legal basis?

  Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

  We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

• Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.

5. How We Obtain Your Consent

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by email, post or telephone using the contact details set out in the “How to Contact Us” section above.

6. Our Use Of Cookies And Similar Technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other technologies we use, the purposes for which we use them and how to manage, block or delete them.

7. Third-Party Links And Services

Our Site contains links to third-party websites and services. When you use a link to go from our Site to another website or you request a service from a third-party, this Privacy Notice no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal information collected by us through our Site, the supply of our products and services and/or in connection with our business operations and does not apply to these third-party websites and third-party service providers.

8. Sharing Data

We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information and to comply with our data protection, confidentiality and security standards. When processing your personal information we may need to share it with the third parties described in the “Personal Information We Collect and How We Use It” section above).

9. Transfers Outside The EEA

Where necessary in order to deliver our services, we will transfer personal information to countries outside the European Economic Area. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

Some of our third-party providers are located in the USA and their use of your personal information is governed by the EU-U.S. Privacy Shield.

10. How Long We Keep Your Personal Information

Regarding personal information we have processed in connection with the supply of our products and services to any customer, we will retain personal information relevant to that supply of products or services for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information for [e.g. three] years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we know not to send you further marketing communications in the future.

11. Confidentiality And Security Of Your Personal Information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site and our products and services.

12. How To Access Your Information And Your Other Rights

You have the following rights in relation to the personal information we hold about you:

• Your right of access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
• Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to erasure. You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
• Your right to restrict processing. You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
• Your right to data portability. You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to a third-party of your choice.
• Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:
  • relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing;
  • processing your personal information for the purposes of personalised direct marketing; or
  • processing your personal information for the purposes of non-personalised direct marketing.
• Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
• Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
• Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

13. Changes To This Privacy Notice

We may make changes to this Privacy Notice from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.