Your privacy is important to us. At Sunderland Translations, we want you to be confident that the information you give us when using our site is safe and secure. In this Privacy Policy we’ll explain how Sunderland Translations use your data to provide you the best possible, more personalised experience, and why we collect your personal information, what rights and choices when it comes to these details as well as the key actions we take to keep your data secure and confidential.

Updated: 16 July 2019

1. What this Privacy Policy covers

This is the Privacy Policy for Sunderland Translations, Sunderland Translations Websites, “The Site”, related mobile applications or other similar devices and our tools.

Sunderland Translations are committed to putting the businesses we work with first and being transparent on how we collect, use and protect your personal information. The data controller is Sunderland Ventures Ltd (referred to in this policy as “we”, “us” or “our”). We want you to be confident that the personal information you give us is safe and secure with us, and understand how we use it to offer you a better and more personalised experience on The Site.

Our Privacy Policy explains:

• the personal information we collect;


• how and why we collect and use your personal information;


• why we process your personal information;


• when and why we will disclose your personal information internally, or to other organisations;


• the rights and choices you have when it comes to your personal information;


• why we use cookies;


• the steps we take to ensure your information is kept secure and confidential;


• how long we will hold your information for; and


• how to contact us.

Our Site contains links to third-party websites that are not subject to this Privacy Policy. Read our Terms and Conditions for further information on these links and what they are used for. We’d always recommend that you read a third party’s terms and conditions and privacy policy carefully before providing any personal information on a third-party website, as we cannot accept any responsibility or liability for those third-party websites.

2. Personal information we collect about your business

• When you register for the Sunderland Translations emails you must provide us with your email address and name


• When you join any of Sunderland Translation’s subscription programs, you must provide us with your email address and name


• When you make an order/purchase through Sunderland Translations you may be asked to provide us with the following personal details about your business, including but without limitation to your name, postal and billing addresses, email addresses, phone numbers, date of birth, title, marital status, dependants, employment status, income and primary bank


• When you register interest for any Sunderland Translations product you must provide us with your email address, name, organisation, business finance requirements, and telephone number

3. How we collect and use your business information

This section explains how we collect and use your business information.

3.1. Sunderland Translations News Update emails

We collect your email address and name when you register to receive our Sunderland Translations News Update emails. This is usually weekly, but on occasion we may send a special edition when we have something really exciting or important to share with you and it doesn’t happen very often.

3.3. Sunderland Translations Competitions, Nominations and Scholarships

We may collect your email address and name, and additional information if you’re entering Sunderland Translation’s Competitions, Nominating yourself, another person, your company, or another company. If you’re providing us with another person’s or another company’s personal information you should first ask them to read this Privacy Policy and our Terms and Conditions. By giving us personal information about another person you are confirming that they have given you consent to provide the personal information to us and that they understand how their details will be used.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 12 below).

3.4 Sunderland Translations Language Services Products

We collect your personal information from you when you request certain products via forms on our Site. We use this so that we can manage your request.

If we need to pass your personal information to a third party to meet your request, we will make it clear at the time you submit your details. In accordance with section 1 above, we recommend that you read the privacy policies of those third parties.

3.5. Comments

We collect and use your email and IP address to enable you to post on The Site. We use your email address to send you your password to enable you to log in to our Forum and to send you email notices if you have elected to receive them. We also use your email and IP addresses for admin, troubleshooting and investigatory purposes, as well as to prevent spam.

3.6. Internal reporting, insight and analysis

We may also use the personal information referred to in this section 3 to generate aggregated, anonymised data for the purposes of internal reporting, insight and analysis, enabling us to improve and personalise our Site, the products we offer and search results for our Site. Where necessary this exercise may be carried out on our behalf by a third party – please see section 7 below.

3.7. Site personalisation

We may use the information you provide us to personalise aspects of our Site, enable your details to be moved across our tools to speed up form filling and for market research. As part of this, we may match your personal information against information that has been collected by a third party. We are always working to make a better Site for you and using your personal information in this way helps us to do this. It also means that if you’ve given us permission, any email we send to you is appropriate for your needs.

3.8. Contacting you

We collect and may use the information you provide to us to:

3.8.1 contact you in response to the communications that you have directed at us. We want to be able to help you so we use personal data to provide clarification or assistance in response to your communications;

3.8.2 invite you to take part in surveys, polls and other market research activities carried out by us and by other organisations on our behalf. Any feedback you provide will only be used to improve our Site and will not be published. However, if we contact you about this, you do not have to take part in the activities;

3.8.3 award you a prize if you have won a competition we’re running.

If you’re providing us with another person’s personal information you should first ask them to read this Privacy Policy and our Terms and Conditions. By giving us personal information about another person you are confirming that they have given you consent to provide the personal information to us and that they understand how their details will be used.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 12 below).

4. Why do we process your personal information?

We will only collect and use your personal information (as described in sections 2 and 3) in accordance with data protection laws. Our grounds for processing your personal information are as follows:

Consent – Where necessary we will only collect and process your personal information if you have consented for us to do so.

Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are:

• to enable you to access and use the Site;


• to follow up on expressed interest on the Site;


• to communicate with you about your use of Sunderland Translation’s Tools and Products; and


• to improve our Site. We may use your personal information to undertake demographic and geographic segmentation and generate anonymised profiling information to help us understand what you might be interested in and for market research. We are always working to make Sunderland Translations a better Site for you and using your personal information in this way helps us to do this.

From May 2018, you will have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us (see section 8 below).

5. Use of children’s personal information

We do not knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian’s permission before you provide any personal information to us.

6. Sharing your personal information with Sunderland Translations

Sunderland Translations might share the following information across Sunderland Ventures-owned websites, that includes;

6.1. Any personal information about you, including contact details (as opposed to aggregated or anonymised user behaviour data), we gather while operating our Site shall not be tracked or otherwise used by Sunderland Translations without your informed consent (except for internal reporting, accounting or compliance purposes);

6.2. If you give separate informed consent for your personal information to be shared across the Sunderland Ventures it may then be used to speed up form filling, or to personalise or improve your experience if you then go to those websites;

6.3. If we send you directly to Sunderland Venture’s websites or you visit them independently, your personal information shall be subject to those websites’ privacy policies; and

6.4. Any of your personal information, including contact details, gathered while operating our Site shall not be sold to third parties or used for the purposes of unsolicited communications from other parts of Sunderland Ventures.

7. Disclosure of your personal information to other organisations

The personal information that we collect when you use our Site is confidential. We may disclose your personal information to a third party in the following circumstances:

7.1. If required or permitted to do so by law;

7.2. If required to do so by any court or any other applicable regulatory, compliance, governmental or law enforcement agency;

7.3. If necessary in connection with legal proceedings or potential legal proceedings;

7.4. If ownership of all or part of our Site is transferred, in which case any purchaser would only be entitled to use that information in a way consistent with this Privacy Policy; and

7.5. In line with our own Terms and Conditions (in particular as it relates to reporting offending Comments to their ISP or to the authorities if their actions appear to amount to a crime).

8. How you can change permissions

Your privacy is of huge importance to us. All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe. Plus, if you don’t want to be contacted by us anymore you can email Data.Team@sunderlandtranslations.com. Section 9 below also sets out your other information rights.

9. Your information rights and responsibilities

9.1. You already have certain rights under existing data protection legislation, including a right to request a copy of the personal information we hold on you, if you request it in writing. From 25 May 2018 you will have the following rights:

9.1.1. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;

9.1.2. Right to erase: the right to request that we delete or remove your personal information from our systems;

9.1.3. Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;

9.1.4. Right to data portability: the right to request that we move, copy or transfer your personal information;

9.1.5. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal information.

We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.

9.2. To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact Data.Team@sunderlandtranslations.com.

9.3. If you’re not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner’s Office.

10. Cookies

10.1. We use cookies (files which are sent by us to your computer or other access device) and tracking technology to help to improve the functionality and performance of our Site.

10.2. The information derived from our use of cookies will be aggregated to provide statistical information about the usage of our Site. However, we do not use any information derived from cookies, nor any IP addresses we collect, to identify any individual user of our Site.

10.3. Some third-party technology we use (eg, embedded videos, social sharing) also drop cookies to improve your experience on their sites.

10.4. For details on what cookies we use, information on how to stop them being stored or how to delete ones already stored, read our Cookie Policy.

11. Keeping your personal information secure

11.1. Keeping information about you secure is very important to us so we store and process your personal information in accordance with the high standards required under data protection legislation. From time to time and for operational reasons the personal information we collect from you may be transferred to and stored in countries outside of the European Economic Area (“EEA”). Your information may also be processed by some of our service providers which operate outside the EEA. Different countries have different data protection and security laws and some of these do not offer the same level of protection as you enjoy under UK data protection legislation. However, when we appoint our service providers to help us provide products and services to you (which may include some based in the USA), we take care to ensure that they have appropriate security measures in place.

11.2. We do our best to keep the information you disclose to us secure. However, we can’t guarantee its security. By using our Site you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

12. How long do we keep your personal information?

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted. If, having registered for any of our services and you do not use them for a reasonable time (which may vary depending on the service(s) you’ve registered for), we may contact you to ensure you’re still happy to receive communications from us. Even if we delete your personal information it may persist on back-up or archival media for legal, tax or regulatory purposes.

13. How to contact us

Our Data Protection Officer is Sunderland Translation’s Director.

If you have any queries relating to our use of your personal information or any other related data protection questions, please contact Data.Team@sunderlandtranslations.com.

14. Changes

This policy is effective from 24 May 2018 and replaces with immediate effect other previously published policies. We may, from time to time, make changes to this Privacy Policy to reflect any changes to our privacy practices in accordance with changes to legislation, best practice or Site enhancements. We will let you know what these changes are by posting them to this page. Where the changes are significant, we may also choose to email you with the new details and get your consent to make these changes where required by law. It is your responsibility as a user to make sure that you are aware of changes posted on this page, by checking for any changes on a regular basis. Changes posted on this page will become effective as soon as they are posted.