Transpose SA Privacy Policy

Art. 1: Privacy Notice

Transpose SA provides its Customers with linguistic, document processing and translation services, as well as related advice, hereinafter referred to as Services. In this context, we at Transpose SA make a firm commitment to ensure that the information you provide remains private and used only for the purposes stated below. This Privacy Policy specifies and informs you on how your personal data as a data subject and/or Customer is collected, used and shared when you contact us or when you use our Services.

We encourage you to read this Privacy Policy before using this Website. Updates to it will be communicated through our Website, so please check back periodically. It was last updated on 24 June 2020.

Art. 2: Scope of our Privacy Policy

This Privacy Policy refers strictly to Transpose SA, a Company Limited by Shares registered with the Commercial Register of the Canton of Geneva under number CHE-100.836.915, with its registered office on Avenue Calas 8, 1206 Geneva, Switzerland. Transpose SA is the data controller for the information you provide.
We can be contacted at trp@transpose.ch.
Our Privacy Policy applies to any information we collect by any means, including through our Website, e-mail, telephone, or information provided orally by our Customers. Once you cease to be our Customer, we continue to use and share your data as described below.

You are notified of our Privacy Policy when you use our Website, and when we respond to your request with a quote. Please read the following provisions carefully. If you disagree with the specifications provided by the Privacy Policy, please notify us immediately at trp@transpose.ch. Without such notification, the use of this Website signifies that you agree with all terms of this Privacy Policy.

Art. 3: Collected Data

3.1 When Using Our Services
When you use our Services, we may ask you to provide us with certain personal information needed for your identification, such as your name and, if applicable, the name of the company you represent, your occupation, your full address, your e-mail, as well as data relating to the payment of invoices, such as bank or credit card details, data related to your tax system (tax ID, domiciliation, etc.). We need such personal data to be able to contact you and provide you with the requested Services (such as providing a quote, customer support, documents delivery or billing). This falls under the scope of our legitimate interests as a business. If you do not agree with one or more aspects of this data collection policy, please be aware that our Services may be drastically reduced or unavailable.
For security reasons and to prevent any fraud, we may ask you for additional information to check your identity, your address, your solvency or such other similar information, imperative for the risk management and for the compliance with the regulatory aspects governing the performance of our Services. This falls under the scope of our legitimate interests as a business.
When you voluntarily exchange business contact details with us, we may use your personal data for advertising and marketing if we have your consent to do so, or if we consider it in our legitimate interests to maintain a business relationship with you or the company you represent.

3.2 Use of Cookies
By using various cookies, our Website automatically receives and records information about your connection to our Website, including your IP address, the date and time of visit, the country you are visiting us from, and the type of search engine used.

The cookies indicated above help us administer the Website and improve your browsing experience by personalizing the Website. They are thus collected on the basis of the legitimate interests of Transpose SA. We believe that your experience of the Website would be adversely affected if you opted out of the cookies we use.
Any additional cookies, such as interest-based advertising cookies, require your consent. You can choose which types of cookies you agree to, and withdraw your consent at any time.

Art. 4: Use of your Personal Data

We use the information mentioned in Art. 3 to:

  • Check if you already exist in our databases
  • Stay in touch with you and be able to contact you regarding the services you have requested
  • Be able to analyze your request for Services and provide you, if necessary, with a detailed estimate
  • To inform you of the status of your orders (e.g. production notice, delivery notice, billing notice, etc.)
  • To manage the feedback and quality process, billing and order closing procedures
  • To provide you with new offers, services, promotions or details about new products we consider that may be of interest to you. You can at any time notify us that you do not wish to receive this type of communication at trp@transpose.ch.

Transpose SA does not sell to third parties data provided directly or indirectly by its Customers. We only share data for the purpose of achieving our mandate in the most effective manner and to provide you with the best quality services, or to inform you of new service opportunities.

4.1 Sharing of your Personal Data
In order to analyze your request for Services and to perform these Services, your personal data can be shared with different interlocutors or collaborators, such as our internal translators, embassies and consular Services, notary offices, courier or postal Services, our other production sites or our administrative and technical employees. Our collaborators are bound by a written agreement which commits to appropriate safeguards in relation to the handling of your personal data.
Transpose SA does not sell to third parties data provided directly or indirectly by its Customers.
We may also disclose your personal information in response to legal action, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or act regarding illegal activities, and as otherwise required by law.

4.2 External Web Services
We use Google Analytics to track visitors. You can read Google Analytics’ terms of service here.
Our Website may also link to other websites. If you provide any personally identifiable information through any such third-party website, data processing will occur on such third party’s website (and not on this Website) and the personally identifiable information you provide will be collected by it on their own servers, and controlled by the privacy policy of that third party. We recommend that you review the privacy policy of these sites.

Art. 5: Scope of our Liability
Our confidentiality commitment is limited to the information that Transpose SA collects from its current or prospective customers. We exclude all liability for the information contained in the documents provided to Transpose SA for the performance of its orders. The Customer is solely responsible for anonymizing, if necessary, the content of the documents to be translated or for providing us with the necessary instructions regarding the confidentiality of such documents. Content sharing is imperative if it concerns documents having an official nature and whose processing involves the intervention of third parties, such as, without limitation to, public officers, consular officers and notary officers, which is required for the fulfillment of our order.
We do not share the data of our Customers. More specifically, all translation memories and glossaries relating to them are not interlinked between the different files entrusted by our Customers. Finally, the data entrusted by our Customers is not processed in public translation or text analysis engines.

Art. 6: Data Retention
The length of time Transpose SA retains its Customers’ personal data will depend on any legal obligations we have, the nature of any Agreements we have in place with you, the existence of your consent or our legitimate interests as a business.
The information that you send for the purpose of an inquiry will be kept for as long as is required to respond and complete your inquiry, and for a further 12 months before deleting your information, unless you provide consent for future contact during your inquiry.
In all cases and for reasons of traceability and quality management, Transpose SA keeps a copy of the documents relating to carried out orders. Our translation management software safely stores a copy of the processed documents for 3 years. After termination of an Agreement with a Customer, we retain their information for a period of 10 years following the end of the financial year during which the Agreement was completed. This is the period of retention required by Swiss law. Processing of contractual data will however remain limited after termination of the Agreement.
Our archives are kept in accordance with the legal provisions in force in Switzerland. In addition, we maintain records of our legal or regulatory obligations, such as audits and certifications. If you would like to know which information is concerned by this, you can contact us at trp@transpose.ch.

Art. 7: Data Protection and Storage
Transpose SA’s archives are stored in Switzerland with ISO 27001 security standards-compliant proprietary infrastructure and firmware. These archives are protected by physical means, such as alarm and video surveillance systems on our premises, external security companies for the surveillance of our premises, electronic means of protection, such as physical firewalls and software, processes and means of data encryption and internal procedures, such as the sharing of information with our employees on a “need to know” basis.
Transpose SA strives to ensure the highest security of its archives. However, we cannot guarantee absolute security or full protection against systemic risks, such as possible cyber-attacks and data theft. For this purpose, Transpose SA regularly conducts external security audits, both scheduled and random, performed by leading IT security companies based in Switzerland. We will notify you of the intrusion in our system concerning your personal data, within 48h from its discovery, by using the contact information you have provided us with.
We are available to assist you in the traceability of your data. Requests in this respect can be sent to us at trp@transpose.ch.

Art. 8: Your Rights as a Data Subject
You have the right to:

  • Opt out from your personal data being processed for direct marketing purposes;
  • Request information regarding the processing of your personal data, including being provided with a copy of your personal data;
  • Request the correction and/or deletion of your personal data, or object to the processing of your personal data; and
  • Request the restriction of the processing of your personal data.

If you object to the processing of your personal data, we will respect that choice, provided that it doesn’t interfere with our legal obligations.
If you would like to exercise any of your rights, please let us know by getting in touch at trp@transpose.ch.

Art. 9: Integrality
Our Privacy Policy is an integral part of our Agreements with our Clients, our General Terms and Conditions (GTC) and our Website’s Terms of Use.

Art. 10: Severability
If any provision of this Privacy Policy is found to be unenforceable, only such provision will be void. The remainder of the Privacy Policy shall stand fully enforceable.