Privacy Policy

1. Who we are

Company: TT&C Translation Services Limited
Trading names: TTC Translation Services / The Translation Company
Company registration number: 644045 (Ireland)
Contact and business address: 2nd Floor, 5-7 Upper O’Connell Street, Prosperity Chambers, Dublin 1, D01 P5P5, Ireland
Email: [email protected]
Phone: +353 1 254 6166
WhatsApp contact numbers: +353 89 951 1020 / +353 89 960 2232
Website: thetranslationcompany.ie

For website enquiries, quotations, our customer relationships, billing and our own business administration, we normally act as the data controller. This means that we decide why and how personal data is processed.

For document processing undertaken solely on a business client’s documented instructions, our role may instead be that of a processor under a separate data-processing agreement. Our role depends on the actual processing, not simply on how a contract labels it. Where another organisation is the controller, we assist it with rights requests and direct you to it where appropriate.

2. What this policy covers

This policy covers our website and landing pages; quotation and document-upload forms; email, WhatsApp, phone and other customer communications; translation and related project work; CRM and workflow systems; billing and accounting; and advertising and analytics where lawfully used.

It does not replace the privacy notices of independent third-party websites or services. Section 15 explains how those services may be involved.

3. Personal data we collect

3.1 Contact and enquiry details

These may include your name, email address, phone or WhatsApp number, country, language pair, document type, service requested, deadline, preferred delivery method and message.

3.2 Documents and translation materials

You may provide copies, scans, photographs or digital files, including birth, marriage and divorce certificates; passports, identity cards and driving licences; academic, employment and immigration records; police-clearance and court documents; company documents; and medical or financial records. Documents may concern you or other people, including children, relatives, employees or clients.

Depending on their contents, documents may contain health information, racial or ethnic origin, religious beliefs or other special-category personal data. Biometric information falls within the special-category rules where processed to uniquely identify someone. Information about criminal convictions, alleged offences and related proceedings is subject to separate legal rules. Not every identity document, family detail or financial record is automatically special-category data.

3.3 Orders, payments and billing

We process quotations, order details, payment status, invoice and billing information, transaction references and accounting records. We do not intentionally store full payment-card details on our website. Banks and payment providers may process payment information under their own privacy notices.

3.4 Communications

We may retain relevant emails, WhatsApp messages, telephone notes, instructions, order updates, revision requests, complaints and delivery communications.

3.5 Website, advertising and analytics information

Depending on the features used and your choices, information may include IP address, browser and device details, pages visited, referral source, approximate location, consent choices, campaign parameters, click identifiers and conversion information. Relevant tools may include Google Ads, Google Analytics, Google Tag Manager, Microsoft Clarity, form tools, CRM and automation systems, and communication providers.

Optional analytics and advertising cookies, local storage and similar technologies requiring consent are subject to prior consent. Section 10 explains the distinction from strictly necessary functions. Permission to process a quotation is not permission to use its contents for advertising.

3.6 Reviews and testimonials

We may process review names, ratings, review content and feedback. Publication requires an appropriate lawful basis and must respect the permissions and visibility of the original review.

3.7 Information needed to provide a service

Information marked as required in a form, or requested when preparing your order, is needed to identify and respond to your enquiry or carry out the agreed work. Without essential contact details, legible materials or necessary instructions, we may be unable to quote or provide the service. Optional uploads and messages are identified where applicable. You do not have to agree to optional marketing to request a quotation.

3.8 Administrative automation

Workflow tools may assist with routing enquiries, recording attribution and updating order records. Those functions are distinct from a decision made solely by automated processing which has legal or similarly significant effects. Before any such significant automated decision-making is used, we must identify a lawful basis, explain its logic and likely consequences, and provide the safeguards and rights required by law.

4. How we collect personal data

We collect information when you use our forms, upload documents, contact us, request a quotation, place an order, pay, request a correction, interact with our website or advertisements, or leave feedback.

We may also receive relevant information from business clients, authorised representatives, family members, translators, revisers, project managers, payment providers, public sources or other service providers. Where information is obtained from someone other than the individual concerned, we provide the information required by Article 14 GDPR within the applicable period, unless a lawful exception applies. A customer’s authority to send a document does not remove TTC’s own obligations.

5. Why we use personal data and our legal bases

5.1 Enquiries and quotations

We use contact details, document samples and instructions to assess a request, discuss requirements and prepare a quotation. Where you are the prospective customer, the basis is taking steps at your request before entering a contract, where necessary. For business representatives or other relevant contacts, the basis may be our legitimate interest in responding to and administering the enquiry, subject to the individual’s rights.

5.2 Translation and related services

We use necessary documents, instructions and contact details to translate, certify, revise, deliver and manage the agreed service. Where you are a party to the service contract, the basis is performance of that contract. For other individuals’ data, we identify the applicable basis separately; our contract with a customer is not automatically a contractual basis for everyone mentioned in their documents.

Special-category data requires both an Article 6 basis and an applicable Article 9 condition. Depending on the circumstances, that additional condition may be the data subject’s explicit consent or necessity for establishing, exercising or defending legal claims. We identify the relevant condition and safeguards for the work. Simply accepting our Terms, uploading a document or having a translation contract is not, by itself, an Article 9 condition.

Criminal-conviction, offence and related information is considered separately under Article 10 GDPR and section 55 of the Irish Data Protection Act 2018. Where the individual concerned is a party to the contract, section 55 can permit necessary and proportionate contractual processing, subject to an Article 6 basis and suitable and specific safeguards. In other circumstances we must identify a different applicable section 55 condition before processing. We do not assume every police-clearance document requires the same consent procedure.

5.3 Customer communications

We use contact details to send quotations, payment instructions, questions, updates, translations and support communications. The basis is performance of a contract or pre-contractual steps where applicable, or our legitimate interest in providing and administering customer service for other relevant contacts.

5.4 Payments and records

Billing and accounting processing supports payment, receipts and compliance with tax and accounting duties. The bases are performance of the contract and compliance with applicable legal obligations.

5.5 Security, misuse, complaints and legal rights

Our legitimate interests include protecting systems and customers, preventing fraud, resolving complaints and defending legal rights. Legal obligations may also apply. We assess necessity, proportionality and the impact on individuals; legitimate interests do not override requirements for cookie consent or conditions for sensitive data.

5.6 Service and website improvement

Necessary fault diagnosis and service administration may rely on legitimate interests. Optional analytics cookies or similar device access require consent. The fact that an activity improves our website does not make every associated tracker strictly necessary.

5.7 Advertising and conversion measurement

Where lawfully enabled and supported by the required consent, we may measure advertising visits, enquiries, contact actions and paid orders. Disclosures must identify the relevant purposes, data categories and recipients. Any use of contact-data matching requires its own applicable disclosure and legal basis; hashing contact data does not automatically make it anonymous. A document sent for translation is not a grant of permission to disclose its contents to an advertising platform.

5.8 Marketing communications

We send electronic marketing to individuals with their consent unless a lawful exception applies. The existing-customer exception is limited to our own similar services, contact details obtained in the context of a sale, an easy opt-out at collection and in each message, and the applicable time conditions. An unconverted quotation enquiry does not by itself make someone an existing customer for that exception.

You may object to direct marketing or withdraw marketing consent at any time without charge. This does not stop communications needed to answer your enquiry or fulfil an existing order.

Technology-assisted processing

TTC may use electronic document-management systems, text-recognition tools, translation memories, machine translation and artificial-intelligence-assisted tools to support document assessment, translation, revision, quality checks and service administration. Where these tools process personal data, their use must be appropriate to the agreed service and subject to applicable confidentiality, security and data-protection requirements. Technology-assisted processing does not remove TTC’s responsibility for the agreed service or replace the professional review and certification required for a certified translation.

Use depends on the service, agreed requirements and the tools assessed for the work. This does not mean that every document is processed using each technology. Allowing a provider to reuse customer content to train a general-purpose model would be a separate purpose requiring its own assessment, transparency and lawful basis; sending a document for translation does not grant blanket permission for that reuse.

6. Sensitive documents and third-party data

Only send documents that you are authorised to provide. Where a document concerns another person, tell us enough about the intended service and your authority to enable appropriate handling. Authority to transmit a document and consent for every possible use are not the same thing.

For quotation purposes, avoid unnecessary personal information. You may redact details that are not needed to assess the work, provided the remaining sample still permits an accurate quotation. A complete, legible source may later be needed for the translation itself. Contact us before sending particularly sensitive material if you need to discuss a suitable transfer method.

7. Children’s data

Our services are intended for adults and organisations, not for direct purchase by children. Customers may nevertheless provide children’s birth certificates, school records, family or immigration documents.

If you submit a child’s document, you must be the parent, guardian or otherwise authorised person. We still assess our own legal basis, necessity and safeguards; this statement is not a blanket waiver of a child’s privacy rights.

8. Who we share personal data with

Where necessary for the purpose concerned, recipients may include translators, revisers, proofreaders and project managers; certification, notarisation, apostille or legalisation providers; IT, hosting, security and cloud providers; CRM, form, workflow and relevant technology-assisted-processing providers; email, telephone and WhatsApp providers; banks, payment and accounting providers; postal and courier services; professional advisers and insurers; and public authorities where disclosure is legally required.

Advertising or analytics providers receive information only within the applicable lawful arrangements and consent choices. Access should be limited to what each recipient needs: a payment or postal provider does not ordinarily need the complete contents of a translation document.

Processors acting on our instructions require appropriate data-processing terms, confidentiality and security obligations. Independent controllers, such as some payment or communications providers, have their own responsibilities. Contact us for information about the recipients relevant to your enquiry or order.

9. International transfers

Some translators, communication, technology, support or cloud providers may operate outside the European Economic Area (EEA). Remote access from outside the EEA can also constitute a transfer.

A transfer must have an applicable Chapter V GDPR mechanism, for example a relevant European Commission adequacy decision or appropriate safeguards such as the applicable EU Standard Contractual Clauses, together with necessary assessment and supplementary measures. Confidentiality promises and access controls support protection but do not, by themselves, replace a lawful transfer mechanism.

Where a transfer applies, information about the recipient, destination country and relevant mechanism must be made available for the processing concerned. You may request details and a copy or description of relevant safeguards using the contact details in section 18, subject to lawful redactions. An exceptional transfer derogation is not a routine substitute for establishing appropriate safeguards.

10. Cookies and similar technologies

Cookies and comparable technologies include local storage, pixels and other ways of storing information on, or accessing information from, your device.

Functions strictly necessary to transmit a communication or provide a service you explicitly request may operate without cookie consent. Other analytics, advertising and conversion-tracking device storage or access requires prior consent. This distinction depends on the purpose, not whether a tool is called first-party, server-side or anonymised.

Where optional technologies are offered, the consent information must identify their purposes, providers, names or types and durations, allow a genuine choice, and provide an accessible way to change or withdraw consent. Refusing optional tracking must not prevent a basic quotation request. Continuing to browse is not consent, and a Privacy Policy link is not a consent mechanism.

Where optional tracking is enabled, accessible cookie-preference controls must let you vary or withdraw your choices. Contact us for assistance. Browser settings may also remove or restrict stored information, but are not a substitute for the choices TTC must provide. Withdrawal does not affect processing that was lawful before withdrawal.

11. How long we keep personal data

We retain personal data only for as long as necessary for an identified purpose and applicable obligations. We are introducing a structured retention schedule and reviewing older records across our working systems and archives. The following are our target periods and review criteria; their introduction does not mean that every historical copy has already been deleted.

• Documents for an enquiry that does not become an order: normally delete 90 days after the enquiry closes, unless a specific continuing need is recorded.
• Basic quotation correspondence and details: up to 12 months after closure where needed for follow-up or accountability, avoiding unnecessary document attachments.
• Completed translations and necessary source material: normally up to 24 months after delivery for redelivery, corrections and documented project needs. Unnecessary duplicates should be removed sooner. Sensitive medical, police and identity documents require a stricter necessity assessment.
• Invoices and necessary accounting records: retain for the applicable statutory period, generally six years, with longer retention where a legal requirement or hold applies. This does not automatically justify retaining every source document for that period.
• Minimum certification and issuance records: kept separately for as long as necessary for legitimate verification and evidential purposes. The necessary data and period depend on the record and applicable requirements; they do not require keeping the full document in every case.
• Marketing, consent and preference records: kept while needed to demonstrate permission or honour an objection. Limited suppression information may remain after an opt-out to avoid contacting the person again.
• Complaints, disputes and legal holds: preserve the relevant records for the justified period needed to resolve the matter or establish, exercise or defend legal rights.

Extended retention and archived records

Some records may need to be retained beyond our usual retention periods where required by law or where necessary and proportionate for an identified purpose, such as completing an ongoing service, handling a complaint or dispute, establishing or defending legal claims, or maintaining appropriate certification and issuance records. Any extended retention must be justified and documented, limited to the information needed, protected by appropriate access controls and reviewed periodically. Information must be deleted or anonymised when it is no longer needed and no lawful retention requirement remains.

Archiving a record is not deletion and does not create a separate exemption from these requirements. Retention review includes relevant email, messaging, document-management systems, supplier copies, downloads and backup arrangements. A final certified package may include the source document, so keeping that package also retains that source information. Contact us to ask which period or criteria apply to your records or to request deletion; we explain any lawful reason for retaining particular information.

12. Security

We use appropriate technical and organisational measures proportionate to the information and risk. Relevant measures include access restrictions, secure transfer and storage arrangements, confidentiality obligations, data minimisation, staff procedures and appropriate disposal.

No internet transmission method is completely secure. Do not send more sensitive information than necessary. Contact us to discuss a suitable means of providing documents where the ordinary channel is not appropriate. Our legal duties to protect information are not excluded by this warning.

13. Your data-protection rights

Depending on the circumstances, you may request access, correction, erasure, restriction or portability; object to processing based on legitimate interests; and withdraw consent. You may object to direct marketing at any time, including related profiling. Withdrawal does not affect the lawfulness of processing carried out before it.

Contact [email protected] or write to our business address. Requests are normally handled without charge. If there are reasonable doubts about identity, we may request proportionate verification.

We respond without undue delay and normally within one month. Where the law permits an extension for complexity or the number of requests, we may extend by up to two further months, telling you within the first month and explaining why. If we cannot take the requested action, we explain the grounds and your available complaint and judicial remedies.

You may complain to the Irish Data Protection Commission or another competent supervisory authority, including in the EEA country where you live or work or where an alleged infringement occurred. You do not have to complain to TTC first.

14. Accuracy of documents and instructions

Certified translations must accurately reflect the source. If a name’s spelling or transliteration needs to match a passport or other official record, tell us before work starts and provide relevant supporting evidence where needed.

We do not alter substantive dates, names, qualifications or other facts contrary to the source. Where appropriate, discrepancies may require a translator’s note or correction of the original by its issuer.

15. Third-party links and platforms

Our website may link to payment, WhatsApp, social media, Google or review services. Independent providers explain their own processing in their privacy notices. Contacting us through a third-party platform may involve that provider’s processing as well as TTC’s.

A third party’s own notice does not remove TTC’s responsibility for our choices of tools, disclosures or any processing we control.

16. Business transfers

If we restructure, sell or transfer part of the business, relevant personal data may be disclosed or transferred only on an appropriate legal basis, with proportionate safeguards and required transparency. A business transaction is not unrestricted permission to repurpose customer documents.

17. Changes to this policy

We may update this policy as our services, processing or legal obligations change. The current approved version and its effective or last-updated date will be available on our website. Where required, material changes or a new purpose will be explained before the new processing occurs, and new consent will be sought where necessary.

18. Contact us

TT&C Translation Services Limited
TTC Translation Services / The Translation Company
2nd Floor, 5-7 Upper O’Connell Street, Prosperity Chambers, Dublin 1, D01 P5P5, Ireland
Email: [email protected]
Phone: +353 1 254 6166

For the terms applying to an agreed order, see our Terms of Service. Reading this policy or asking for a quote does not by itself constitute optional marketing consent.