Privacy Policy

TOPPAN Digital Language Privacy Notice

June 2024

TOPPAN Digital Language Ltd and its subsidiaries, doing business as TOPPAN Digital Language (“TDL”, “we”, “us”) is committed to protecting the privacy and security of your personal information.

This privacy notice (or “policy”) describes how we collect and use personal information about you. Please read this notice carefully to understand our practices regarding your personal information and how we will treat it.

If you have any questions, comments or concerns about any aspect of this notice or how TDL handles your information, please contact our team at privacy@toppandigital.com

Data protection principles

TDL is a “data controller”. This means that we are responsible for how we hold and use personal information about you.

We will comply with data protection law. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• Relevant to the purposes we have told you about and limited only to those purposes; • Accurate and kept up to date; • Kept only as long as necessary for the purposes we have told you about; and
• Kept securely.

The information we collect about you

We may collect personal information from you in several ways, which are explained below.

Contacting us via our website

When you contact us via the Contact Us form on our website or you request a document download, we collect your name, email address, telephone number and job title, in order to be able to respond to you appropriately.

Registering for or attending one of our events

If you wish to attend one of our online or offline events, we will ask you for information such as your name, email address, telephone number, employer and job title in order to be able to manage attendance and to provide you with information about the event. You may also provide us with dietary or accessibility information, if relevant Communicating with us via Social Media platforms

Communicating with us via Social Media platforms

We do not routinely collect personal information from social media interactions within TDL systems. We will only do this as part of a job recruitment process (see “Applying for a job with us”), a supplier recruitment process (see “Applying to become a supplier to us”) or if you ask us to provide you with information (see “Keeping you updated on our business, services and products”).

Providing your information to us offline

If we meet you at an in-person event and you provide us with your contact details, we may collect your personal information in order to be able provide you with information of interest to you. Your ongoing consent will be sought for your personal information to be used for this purpose.

Keeping you updated on our business, services and products

We will keep you updated with relevant information about our business, services and products if you are an existing supplier or customer to us, or have otherwise given your consent to be contacted in this way.

Applying for a job with us

We collect and use personal information supplied by you if you submit a job application to TDL. For the TDL Employment Recruitment Privacy Notice, please follow this link for UK, this link for Spain and this link for Poland.

Applying to become a supplier to us; current and former suppliers

We collect and use personal information supplied by you if you submit a supplier application to TDL (sometimes referred to as a vendor application or linguist application). We collect and use information in relation to you as an individual if you, or the company you work or contract for, supply services to us. For the TDL Supplier Privacy Notice, please follow this link.

Current and former customers

We collect and use information in relation to you as an individual if you receive services from us, as an individual or as an employee of a TDL customer. For the TDL Customer Privacy Policy, please follow this link.

Current and former employees

We collect and use information in relation to you if you are a current or former employee of TDL. For further information, existing employees should contact hr@toppandigital.com and former employees should contact privacy@toppandigital.com

How we will use information about you

We will only use your personal information when the law allows us to. We will generally use your personal information set out in the table below below for the following purposes:

• Consent: you have given clear consent for us to process your personal data for a specific purpose;
• To perform our contract with you;
• To enable us to comply with a legal obligation;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.

We may also use your personal information in the following (probably rare) situations:

• Where we need to protect your vital interests (or someone else’s vital interests).
• Where it is needed in the public interest or the task or function has a clear basis in law.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for doing so.

We may process your personal information without your knowledge or consent where this is required or permitted by law.

Data sharing

We may have to share your data with third parties, including third-party service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the UK or the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third parties related to corporate transactions or regulatory and legal requirements

We may share your personal information with third parties in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to comply otherwise with the law.

Transferring information outside the UK or the EU if you are within the territories of the UK or EU

We will transfer personal information we collect about you to our group companies and servers/hosting partners located in the UK, EU and USA. There are GDPR adequacy regulations in place in respect of the UK and EU but there are no GDPR adequacy regulations in respect of the USA. This means that the USA is not deemed by the UK and EU GDPR to provide an adequate level of protection for your personal information (except in limited circumstances) unless specific safeguards are put in place.

To ensure that your personal information does receive an adequate level of protection, we have put in place a data protection agreement which includes EU GDPR model clauses as well as provisions UK International Data Transfer Agreement provisions governing the transfer of data between our corporate entities and we are only entering service agreements for hosting or other services with Supplier Parties outside the UK and EU where EU model clauses or an IDTA forms part of the contract.

If you require further information about this you can request it from privacy@toppandigital.com.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request from privacy@toppandigital.com.

Third parties will be required by us to only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to protect your personal information and we limit access to your personal information on a need to know basis. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your Rights Under GDPR

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party
• Complain to the Information Commissioner’s office in the UK if you believe we have breached our obligations in respect of your data.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact privacy@toppandigital.com in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@toppandigital.com. If you inform us that consent is withdrawn, we will no longer process your information for the original purpose unless we have another legitimate basis for doing so.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact privacy@toppandigital.com.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at privacy@toppandigital.com

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

ICO helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Our details

Company name: TOPPAN Digital Language (UK) Ltd
Registered address: 125-133 Camden High Street, London, NW1 7JR
We are registered as a Data Controller with the Information Commissioner’s Office (“ICO”) in the United Kingdom, Registration Number ZA211247

A note on the California Consumer Privacy Act (“CCPA”) for residents of California

TDL does not meet the threshold of applicability of the CCPA. More information about the CCPA can be found here. California Consumer Privacy Act (CCPA) | State of California – Department of Justice – Office of the Attorney General

For the avoidance of doubt, TDL does not sell personal information. If you are a California resident and have questions about your privacy, you can still contact us at privacy@toppandigital.com

Your acceptance of these terms

By using this site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our site. Your continued use of the site following the posting of changes to this policy will be deemed as your acceptance of those changes.