Privacy policy

1. Collection and storage of personal data and the nature and purpose of its use

a) When visiting the website

When you visit our website www.toptranslation.com, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected without any action on your part and stored until it is automatically deleted:

• IP address of the requesting computer
• Date and time of access
• Name and URL of the retrieved file
• Website from which the access is made (referrer URL)
• the browser used and the operating system of your computer as well as the name of your access provider.

We process the aforementioned data for the following purposes:

• Ensuring a smooth connection to the website
• Ensuring a comfortable use of our website
• Evaluation of system security and stability and
• for other administrative purposes.

The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the data collection purposes listed above. Under no circumstances do we use the data collected for the purpose of drawing conclusions about your person. We also use cookies and analysis services when you visit our website. You will find more detailed explanations in sections 4 and 5 of this privacy policy.

b) Newsletter

If you register for our newsletter, we will use the data required for this and provided by you to regularly send you our e-mail newsletter based on your consent in accordance with Art. 6 para. 1 lit. a GDPR.

Content of the newsletter: When registering for the newsletter, its content is described in detail. Our newsletters also contain information about our products, offers, promotions and our company.

Application procedure: Registration for our newsletter takes place via a double opt-in procedure. After registering, you will receive an e-mail from us asking you to confirm your subscription to our newsletter. This is the only way to prevent registration with other people's e-mail addresses. In order to be able to prove registration for the newsletter in accordance with legal requirements, we store the time of registration and confirmation as well as the IP address. To subscribe to our newsletter, simply enter your e-mail address. The indication of your name is voluntary and serves solely to address you personally in the newsletter.

Newsletter success measurement: Newsletters that you have consented to receive contain a so-called tracking pixel (web beacon), i.e. a pixel-sized file that is retrieved from the server of our mailing service provider when the newsletter is opened. Technical information, such as information about the browser and your system, as well as your IP address and time of access, is collected as a result of this access. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical information is also collected on whether and when newsletters are opened and which links are clicked on. This information can technically be assigned to individual newsletter recipients. However, we use the evaluations exclusively to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

Legal basis: The newsletter, including performance measurement, is sent on the basis of your consent in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with. § Section 7 para. 2 no. 3 UWG. The registration process is logged in accordance with Art. 6 para. 1 lit. f GDPR and our legitimate interest in the use of a secure newsletter system that serves both our business interests and your expectations and allows us to prove consent.

Deregistration/revocation: You can unsubscribe from the newsletter - and thus withdraw your consent - at any time. You can unsubscribe either by sending a message to the contact options described above or via the link provided for this purpose at the end of each newsletter. After unsubscribing, we may store your e-mail address and the data from the registration process for up to three years. The basis for this is our legitimate interest in being able to prove a previously given consent. The processing of this data is limited to the purpose of defending against claims. Individual deletion is possible upon request if the previous existence of consent is confirmed at the same time.

Shipping service provider: Our newsletter is sent with the help of the external service provider Mailchimp (The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000 Atlanta, Georgia 30308, USA). Mailchimp is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law: www.privacyshield.gov/participant

c) E-mail advertising without subscribing to the newsletter and your right to object

If we receive your e-mail address in connection with the sale of a product or service and you have not objected to this, we reserve the right to regularly send you offers for services similar to those you have already used from our range by e-mail on the basis of Section 7 (3) UWG. This serves to safeguard our legitimate interests, which predominate in the context of a balancing of interests, in an advertising approach to our customers in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR.

You can object to this use of your e-mail address at any time by sending a message to the contact option specified at the beginning of this declaration or via a link provided for this purpose in the advertising e-mail, without incurring any costs other than the transmission costs according to the basic rates.

d) Postal advertising and your right to object

We reserve the right to use your first and last name and your postal address, which we have received from you in connection with the sale of goods or services, for our own advertising purposes, e.g. to send you offers and information about our products by post. This serves to safeguard our legitimate interests, which predominate in the context of a balancing of interests, in an advertising approach to our customers in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.

e) Orders/contracts

In the context of orders/commissions, we collect and process the following data, which are necessary for the mutual, proper fulfillment of the contract. These include:

• First and last name
• Invoice address, street, zip code and town
• Phone number
• E-mail address
• Company name
• EU tax number
• Data for payment processing
• Product interests
• Communication history
• previous inquiries and orders
• Creditworthiness information
• texts to be translated.

Data processing for the purpose of ordering/commissioning is carried out in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntarily given consent and in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the fulfillment of the contract. The data will be deleted at the latest after the expiry of statutory warranty and comparable obligations (e.g. texts to be translated) or, if statutory archiving obligations exist, after their expiry (e.g. inventory data, communication history).

Data transmitted to us in the context of a contract initiation will be processed in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntarily given consent and in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR. The data will be deleted if it is clear that no order will be placed, but at the latest after one year.

f) Translation

The texts sent to us by the customer for translation are stored by us and made available to the translator. Depending on the source and/or target language, transmission to freelance service providers for the fulfillment of the contract takes place on the basis of Art. 6 para. 1 sentence 1 lit. b GDPR or within the framework of an order processing agreement in accordance with Art. 28 GDPR. Unless otherwise agreed, these may also be external service providers and also those in a third country outside the EU or in the USA. The requirements of Art. 44 et seq. GDPR for processing in third countries are complied with (appropriate level of protection through the creation of suitable guarantees such as EU standard contractual clauses, EU-US Privacy Shield). After fulfillment of the order, these documents are stored at the latest until the time of the limitation period for statutory warranty claims. If no order is placed, the source texts will be deleted no later than one year after transmission.

g) Bontity check

In the case of payment on account, Toptranslation commissions a credit agency to carry out an identity and credit check:

• Creditsafe Deutschland GmbH, Schreiberhauer Straße 30, 10317 Berlin.

For this purpose, we transmit your name and contact details to this company. The legal basis for the transfer and processing of your data is our legitimate interest in credit security due to our obligation to make advance payments in accordance with Art. 6 para. 1 lit. f GDPR.

Information acc. Art. 14 GDPR on the data processing taking place at Creditsafe Deutschland GmbH can be found here: www.creditsafe.com/de/de/rechtliches/datenschutzhinweise/datenschutzhinweise-fuer-auskunfteidaten.html

We take appropriate measures to protect the rights and freedoms as well as your legitimate interests. You can challenge decisions made via the contact options listed above and explain your own position to us.

Once the contract has been fully processed, your data processed for this purpose will be deleted or blocked for further processing if statutory retention obligations prevent deletion.

h) Payment

For the purpose of payment, the personal data provided will be forwarded to the respective payment provider. The scope of the transfer is determined by the selected payment method. We will not pass on your data to third parties as part of a SEPA transfer. If you make a bank transfer via Paypal (PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg) or Skrill (Skrill Limited, 25 Canada Square, London E14 5LQ, United Kingdom), your invoice number, invoice amount and the item information relating to your order will be forwarded to Paypal or Skrill. The scope of the use of your personal data is determined by the data protection principles of the respective provider. Data processing is carried out in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the execution of the contract.

i) Disclosure of data to third parties

Your personal data will not be processed or transferred to third parties for purposes other than those listed above unless

• that the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
• that there is a legal obligation for the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR.

3. Applicants and application procedure

For the purpose of handling the application process, we collect and process personal data in accordance with Art. 6 para. 1 lit. b GDPR. If an employment contract is concluded with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If no employment contract is concluded, the application documents will be deleted six months after receipt, unless otherwise agreed and they are no longer required for contract fulfillment or contract initiation.

4. Cookies

We use cookies on our website. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your end device and do not contain any viruses, Trojans or other malware. Information is stored in the cookie that results in each case in connection with the specific end device used. However, this does not mean that we obtain direct knowledge of your identity. On the one hand, the use of cookies serves to make the use of our website more pleasant for you. We use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site. In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your end device for a specified period of time. If you visit our site again to use our services, it will automatically recognize that you have already visited us and which entries and settings you have made so that you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you (see section 5). These cookies enable us to automatically recognize that you have already visited our site when you return. These cookies are automatically deleted after a defined period of time. The data processed by cookies are necessary for the purposes mentioned to protect our legitimate interests and those of third parties in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website. Further information on this can be found on the website of the Federal Office for Information Security www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrowser/Sicherheitsmassnahmen/Cookies/cookies_node.html

5. Analysis tools

The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website. On the other hand, we use tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

a) Google Analytics

We use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as "Google Analytics") for the purpose of designing and continuously optimizing our pages to meet your needs: "Google"). In this context, pseudonymized user profiles are created and cookies (see section 4) are used. The information generated by the cookie about your use of this website such as

• Browser type/version
• operating system used
• Referrer URL (the previously visited page)
• Host name of the accessing computer (IP address)
• Time of the server request

may be transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage for the purposes of market research and the needs-based design of this website. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that an assignment is not possible (IP masking). You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on here: tools.google.com/dlpage/gaoptout . As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking here: www.youronlinechoices.com/de/praferenzmanagement/ An opt-out cookie will be set to prevent future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. Further information on data protection in connection with Google Analytics can be found in the Google Analytics help section at: support.google.com/analytics/answer/6004245

b) Error tracking

If an error occurs when using our systems, our system sends data about the error to third-party providers. The systems of these providers help us to identify and track technical problems with our systems. For this purpose, the following data, among others, is sent to third-party providers for error tracking:

• Browser type/version
• operating system used
• Referrer URL (the previously visited page)
• URL of the request
• Host name of the accessing computer (IP address)
• Time of the server request.

We use the following third-party providers for error tracking:

• AppSignal B.V., Rietwaard 4, 5236 WC 's-Hertogenbosch, Netherlands, contact@appsignal.com
• Bullet 8

6. Tracking and retargeting

We also use cookies in our systems for purposes such as monitoring our advertising campaigns and retargeting, i.e. to show you advertisements for similar products on third-party websites. The measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website and campaigns. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

a) Google Adwords

We use marketing and retargeting services from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") on our website. These services allow advertising campaigns to be displayed in a more targeted manner.

For this purpose, Google executes code and stores cookies when the website is accessed; alternatively, Google can also use comparable technologies. These cookies enable Google to analyze which websites users have visited and which products they are interested in. In addition, information such as the browser, the operating system or the time spent on the page can be analyzed. All user data is processed pseudonymously. This information is collected by Google and transmitted to servers in the USA, among other places.

By setting cookies through Google AdWords, AdWords customers receive information such as the number of clicks on the advertising campaigns in order to be able to recognize the conversion of individual advertising campaigns.

Further information on the use of data for marketing purposes by Google can be found at www.google.com/policies/technologies/ads, their privacy policy can be found at www.google.com/policies/privacy . If you wish to object to interest-based advertising by Google Marketing Services, you can use the settings provided by Google, which you can find at www.google.com/ads/preferences.

The legal basis for the use of this service is Art. 6 para. 1 sentence. 1 letter f GDPR.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

b) Microsoft Bing Ads

We use marketing and conversion tracking tools from Microsoft Corporation (One Microsoft Way, Redmond, WA 98052-6399, USA) on our website. These services allow advertising campaigns to be displayed in a more targeted manner.

For this purpose, code is executed and cookies are stored when the website is called up by the services; alternatively, comparable technologies can also be used. These cookies enable Microsoft to analyze which websites users have visited and which products they are interested in. In addition, technical information such as the browser, the operating system or the time spent on the page can be recorded. No IP addresses or other personal data are transmitted. This information is collected by Microsoft and transmitted to servers in the USA, among other places.

By setting cookies, we receive information such as the number of clicks on the advertising campaigns in order to be able to recognize the conversion of individual Bing Ads advertising campaigns.

Further information on Microsoft data usage can be found at privacy.microsoft.com/de-de/privacystatement .

The legal basis for the use of this service is Art. 6 para. 1 sentence. 1 letter f GDPR.

Microsoft is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

7. Social media platforms

We maintain online presences and company pages in social networks and on social platforms in order to be able to communicate effectively with you and to draw attention to our offers and services.

The social platforms process your data for advertising purposes and create profiles based on your usage behavior. These usage profiles are used to place advertisements based on your presumed interests within and outside these social platforms. For this purpose, cookies are stored on your computer in which your usage behavior and interests are recorded.

The processing of your personal data is based on our legitimate interests in effective information and communication with active customers, interested parties and users on social platforms in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f. GDPR. If you are asked by the respective platform for consent to data processing (i.e. you declare your consent, e.g. by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.

Your data may be processed outside the territory of the European Union. Platforms whose providers are certified in accordance with the EU-US Privacy Shield thus offer a guarantee of compliance with EU data protection standards.

The most effective way to assert your rights as a data subject is to contact the respective provider directly. Only they can access your data directly and delete it or provide information if necessary. You can also contact us for help.

A detailed description of the respective processing and the opt-out options can be found on the following linked pages:

Social media platform Facebook: Our Facebook page www.facebook.com/toptranslation/ is operated jointly with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), on the basis of an agreement on joint processing of personal data (https://www.facebook.com/legal/terms/page_controller_addendum), privacy policy of the provider Facebook: https://www.facebook.com/about/privacy/ Privacy policy specifically for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, possibility of objection/opt-out: https://www.facebook.com/settings?tab=ads

Privacy Shield (guaranteeing the level of data protection when processing data: www.privacyshield.gov/participant

Social network X: We maintain a page on Platform X at twitter.com/toptranslation. The operator is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: twitter.com/de/privacy, (Settings) twitter.com/personalization; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): www.privacyshield.gov/participant.

Social network Xing: The following applies to our page on the Xing platform at www.xing.de: The operator is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Privacy Policy: privacy.xing.com/de/datenschutzerklaerung.

Social network LinkedIn: The following applies to our page on the LinkedIn platform: Operator is: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: www.linkedin.com; Privacy Policy: www.linkedin.com/legal/privacy-policy; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): www.privacyshield.gov/participant; Opt-Out: www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

8. Rights of data subjects

You have the right:

• to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on its details
• in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or incomplete personal data stored by us
• to request the deletion of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims
• in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR
• in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller
• in accordance with Art. 7 para. 3 GDPR, to revoke your consent to us at any time. As a result, we may no longer continue the data processing that was based on this consent in the future and
• to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.

9. Right of objection

If your personal data is processed on the basis of consent or legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR. If you wish to exercise your right of revocation or objection, simply send an e-mail to privacy@toptranslation.com.

10. Data security

We use the TLS procedure within the website visit. As a rule, this involves 256-bit encryption. We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

11. Up-to-dateness and amendment of this privacy policy

This privacy policy is currently valid and was last updated in May 2018. Due to the further development of our website and offers on it or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can access and print out the current privacy policy at any time on the website at www.toptranslation.com/rechtliches/datenschutzerklaerung.