Notes from Nataliya Yena on processing clients’ data

We explain below how we handle your personal data via the Silabot Portal once we receive the translation order. We record all the data we process in a way that is openly available to you.

1. Name and contact details for the data controller

The data controller within the meaning of the German Federal Data Protection Act (BDSG) and the EU General Data Protection Regulation (GDPR) is

  • Nataliya Yena, Offenbacher Landstr. 368, 60599 Frankfurt am Main, Tel.: +49 (0)69 770 19 550, Fax: +49 (0)69 66058127, Email: mail@silabot.de.

2. Data processing for orders via the Portal, Client account

a) Ordering

When you activate an order via our website, made either as a guest or a registered client, we record the following information:

  • Key data: Your first and last name, company name if applicable, postal address, email address (mandatory fields) and your telephone number, IBAN, date of birth and copy of official identity document (optional fields). We need the data in the mandatory fields in order to identify and contact you, and issue our invoice. We will only process these data for the performance of a contract, on the basis of Article 6(1)(b) GDPR. We use the data in the optional fields (such as your phone number or date of birth) to make it easier to contact you and to assert our claims for payment against you. The legal basis for this is our legitimate interests in both effective client communication and asserting our claims (for example in a case of misuse) in accordance with Article 6(1)(f) GDPR.
    We will delete these data when we no longer require them for the above purposes, usually once ten years have elapsed since the end of the year in which you ordered the translation. This ten-year retention period applies because you as our client have the opportunity to get the translated document reissued at a reasonable fixed price for ten years after we have translated it (this may be the case with certified translations of official documents).
  • Invoice information: This information comprises the invoice address, invoice date and amount, and your VAT number if applicable. We process these data because we are legally obliged to do so (§147 Fiscal Code of Germany, AO). The legal basis for processing is Article 6(1)(c) GDPR. We will delete these data when we are no longer obliged to keep them and provided you did not expressly consent to us continuing to keep them (Article6(1)(a) GDPR).
  • Payment information: We process the payment information you share with us (credit card details, name of bank or building society, IBAN and BIC) for the purposes of processing payments and thus to safeguard our legitimate interests; this data processing is therefore based on Article 6(1)(f) GDPR. Where you opt to pay by SEPA direct debit, data processing will occur on the basis of your consent in accordance with Article 6(1)(a) GDPR (see also Section 3(c) of the present Data Protection Notice). We will delete these data when we are no longer obliged to know them in order to fulfil the purpose for which they were stored (when there is no longer a contractual relationship), when we are no longer obliged to keep them, and provided you did not expressly consent to us continuing to keep them (Article6(1)(a) GDPR).
  • Content of communications: In addition, we will process the content of our communications with you, i.e., emails and/or written correspondence, as well as the original document for translation and the translation we have produced. Data processing is necessary for the performance of a contract in accordance with Article 6(1)(b) GDPR. We will regularly store the document for translation and its translation until 10 years have passed from the end of the year in which you ordered the translation, so that we can offer you our 10-year document service (see above), unless you declare that you do not and will not use this service. In that case, we will normally delete these data and the remaining content of our communications once three years have elapsed since the end of the year in which we performed the activity (general limitation period). In the case of certified translations, we may also keep the original document and the certified translation we produce, where their continued storage represents our legitimate interests; Article 6(1)(f) GDPR forms the legal basis for this.
  • We will only ask you to upload your Photo ID (a copy of your official ID card or the photo page of your passport) if your name is written in Cyrillic script in the source text for translation. We ask you to upload this ID so we can correctly reproduce in our translation the way the name is written in Latin script there. In identity documents, names are often written in both Cyrillic and Latin scripts. Unless we check the way, the name is written in your identity documents, we cannot guarantee that we will reproduce your name in Latin script the same way in our translation. However, to check how to write it we only need your name, so please black out (redact) the other information such as your ID card/passport number and photo. The legal basis for data processing is your consent in accordance with Article 6(1)(a) GDPR. You are entitled to withdraw your consent at any time, and this will take effect from that time forwards. This will not affect the legality of any processing which has occurred prior to you withdrawing your consent. We will immediately delete the copy of your official identity documents when we no longer need to know these data in order to fulfil the purpose of storing it, or when you withdraw your consent for processing.

Where data processing is in accordance with Article 6(1)(f) GDPR, you have the right to object under Section 5 of the present Data Protection Notice.

b) Client account

If you submit an order via our Portal, you may register as a client. It is only possible to create a client account if you submit an order.

Opening a client account will allow you password-protected access to the user data we have stored. You will be able to view all the information which you have shared with us using the order form, such as first and last name, company name if applicable, date of birth, delivery and invoice addresses, telephone number, email address and IBAN. You can also view your order information and data on existing or previous orders. Another advantage of registering is that you can perform all the activities relating to your orders yourself online, including submitting and managing orders, cancelling and returning them, changing address and payment details. If you wish to place a new order, you will be able to log in straight away using your email address and password, and will not need to submit the same information all over again.

The legal basis for creating a client account is your consent in accordance with Article 6(1)(a) GDPR. We process this personal data – entered via your client account in the context of ordering – in line with Section 2(a) of the present Data Protection Notice.

You are entitled to withdraw your consent at any time, with effect from that time forwards. Your withdrawal must be in writing; it is sufficient to email: mail@silabot.de. This will not affect the legality of any processing which has occurred prior to you withdrawing your consent.

If you withdraw consent to your data being stored or delete your client account, your data will only be processed in a restricted way during the remaining processing, and deleted after the retention periods set out in tax and commercial legislation, provided you have not explicitly consented to continued use of your data, or until a knowledge of these data is no longer required to fulfil the purpose for which they are stored (when the contractual relationship no longer exists). Legal retention periods notwithstanding, you may delete your client account at any time either by email to mail@silabot.de or using the dedicated functionality in your client account.

3. Passing on data to third parties

We may work with the service providers listed below in order to process your order. They may help us with all or part of the work under contracts we have concluded.

Personal data we have stored may be passed on to shipping companies commissioned with delivery in the context of processing your order, provided they have been commissioned with delivering the translation. In the context of payment processing, we may pass on your payment information to the bank or building society we have commissioned where this is necessary for payment processing. We may also pass on your information to third parties processing your order on our behalf. The legal basis for passing on these data is Article 6(1)(b) GDPR and the purpose is the fulfilment of the contract. Where we do pass on your personal data to third parties, the scope of data transmitted will be limited to the minimum necessary.

In other cases, we will only pass data on to third parties where legally obliged to do so (Article 6(1)(c) GDPR) or if you have given us your explicit authorisation for this (Article 6(1)(a) GDPR); before we ask for your authorisation, we will inform you about the categories of data and purposes of transmission, as well as the purposes for continued data processing. We will not pass on any other information to third parties.

a) Passing on personal data to processors

We use processors to handle your data. ‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Processors do not use these data for their own purposes, instead processing them exclusively on behalf of the controller. We commission external translators as processors; they are under a contractual obligation under the GDPR to keep your personal information confidential. The legal basis for passing these data on is Article 6(1)(b) GDPR.

b) Passing on personal data to shipping providers

We work with external shipping partners in order to fulfil contractual obligations towards our clients. For the purposes of delivery, and in accordance with Article 6(1)(b) GDPR, we will only pass your name and delivery address on to a shipping partner we have selected. We will only pass these on if necessary for the delivery. If you have given your express consent to this during the order process, we will pass on your email address or telephone number to the relevant shipping partner in accordance with Article 6 (1)(a) GDPR so they can coordinate the delivery time or inform you of the delivery. Without the relevant consent it will not be possible to coordinate the delivery time with Deutsche Post or inform you of the delivery in advance.

You are entitled to withdraw your consent at any time, and this will take effect from that time forwards, by contacting the controller designated in Section 1 or the relevant shipping provider. This will not affect the legality of any processing which has occurred prior to you withdrawing your consent.

We commission the following shipping providers:

c) Passing on personal data to financial institutions

Where you choose a relevant payment type, we will pass the necessary payment information on to the bank or building society responsible for payments, so they can process these.

Where you choose payment by SEPA direct debit, we will pass on your information to the relevant bank or building society so they can process the direct debit. The electronic SEPA direct debit mandate form on our website shows which personal data we record for the above purpose. As soon as we have received your completed SEPA direct debit mandate, the data you state in it will be processed to make our claims for remuneration. As part of the direct debit process, the data will be transmitted by data transfer to the financial institution you have named.

The legal basis for processing the data is the direct debit mandate you have issued in accordance with Article 6(1)(a) GDPR (consent). You are entitled to withdraw your consent at any time, with future effect; the data may not be used from that time forwards. Your withdrawal must be in writing, and may be submitted by email to: mail@silabot.de. This will not affect the legality of any processing which has occurred prior to you withdrawing your consent.

We will delete your stored personal data if you withdraw your consent to storage, or when we no longer need to know these data in order to fulfil the purpose of storing them (when the contractual relationship no longer exists). However, we will only delete these data after the retention periods in tax and commercial legislation or other regulations have expired.

4. The rights of data subjects

As a data subject, you are entitled to:

  • Contact us at any time to withdraw the consent you granted previously, in accordance with Article 7(3) GDPR. The effect of this will be that we may no longer continue to process the data for which this consent is required.
  • In accordance with Article 15 GDPR, you may request a copy of the personal data we are processing. You may in particular request information about the purpose of this processing, the categories of personal data, the categories of recipients to whom your data has been or is being disclosed, the planned duration of storage, the existence of a right to rectification, to erasure, to restriction of processing or to object, the existence of a right to lodge a complaint, the origins of your data where we do not store these, and the existence of automated decision-making including profiling and any meaningful information about the logic involved.
  • In accordance with Article 16 GDPR, you may request the rectification of inaccurate or incomplete personal data concerning you which we are storing.
  • In accordance with Article 17 GDPR, you may request the deletion of personal data concerning you which we are storing, provided that processing is not necessary for exercising the right to free expression and information, for compliance with legal obligations, for reasons of public interest or for the establishment, exercise or defence of legal claims.
  • In accordance with Article 18 GDPR, you may ask that the processing of your personal data be restricted: where you contest the accuracy of the data; if the processing is unlawful but you oppose their erasure; if we no longer need the data yet you require the data yourself for the establishment, exercise or defence of legal claims; or if you have objected to their processing under Article 21 GDPR.
  • In accordance with Article 20 GDPR, you are entitled to receive the personal data concerning you which you have provided us with. This should be in a structured, commonly used and machine-readable format and you may transmit the data to another controller.
  • In accordance with Article 77 GDPR, you may lodge a complaint with a supervisory authority. You may usually lodge this with the supervisory authority for your place of habitual residence or place of work, or for our head office.

5. Your right to object

Where your personal data are being processed on the basis of legitimate interests in accordance with Article 6(1)(f) GDPR, you have the right under Article 21 GDPR to object to their processing where grounds exist for this relating to your particular situation.

If you want to exercise your right to object, it is sufficient to communicate this informally using one of the pieces of contact information listed in Section 1.