Definitions and interpretation
|Data||collectively all information that you submit to Dragoman Translation via the Website. This definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (EU) 2016/679 2018;|
|Cookies||a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|XTM International Ltd, we or us||Dragoman Translation, a company incorporated in Turkey with registered number 4217452 whose registered office is at BLACKOUT Plaza Block A Sisli Istanbul;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|GDPR||The General Data Protection Regulation (EU) 2016/679 2018;|
|Data Subject User or you||any third party that accesses the Website and is not either (i) employed by Dragoman Translation and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Dragoman Translation and accessing the Website in connection with the provision of such services; and|
|Data Processor||The organisation processing data. This maybe Dragoman Translation or a third party.|
|Data Controller||The organisation collecting data. This maybe Dragoman Translation or a third party.|
|Website||the website www.dragoman.ist, and the application Nubuto, publicly available at www.nubuto.com or privately hosted by Dragoman Trabslation and made available on your domain. This includes any sub-domains of these sites unless expressly excluded by their own terms and conditions|
- SaaS Products – Nubuto Cloud
It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
What Data do we collect and process?
- We may collect the following Data, which includes personal Data, from you:
- Job Title;
- Contact Information such as email addresses and telephone numbers;
- Demographic information such as post code, preferences and interests;
- Web browser type and version (automatically collected);
- Operating system (automatically collected);
How do we use this Data?
- For purposes of GDPR Dragoman Translation is the “data controller” and or data processor.
- Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
- All personal Data is stored securely in accordance with the principles of the GDPR.
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of promotional materials that may be of interest to you;
How long do we retain this Data?
- We will hold on to your information for as long as you have your account, or we need to provide our products, services or support to you.
- In certain situations, for example, if necessary to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information beyond this period.
- We will not hold your data for any longer than is required.
Your rights as Data Subjects
- You have the right to ask for a copy of any of your personal Data held by Dragoman Translation (“right of access”), where such Data is held.
- You have the right to request your personal Data held by Dragoman Translation be removed (“right to be forgotten”) or to be ported to another provider (“right to portability”).
- You have the right to complain to the data protection regulator in the EU or Turkey,
Who to contact in relation to Data
- All requests in relation to data should be addressed to our Data Controller who can be reached on [email protected]
Third party websites and services
- Dragoman Translation may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Controlling use of your Data
- Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
- use of Data for direct marketing purposes; and
- sharing Data with third parties.
Functionality of the Website
- To use all features and functions available on the Website, you may be required to submit certain Data.
- Data security is of great importance to Dragoman Translation and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
- If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
- We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
- In the event of a Data breach Dragoman Translation shall notify the regulators (ICO) within 72 hours and, if high risk, the Data Subjects within a similar timeframe.
- All Cookies used by this Website are used in accordance with current Turkish, UK and EU Cookie Law.
- Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Dragoman Translation to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- This Website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality cookies||These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
|Targeting cookies||These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.|
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
Transfers outside the European Economic Area
- Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
Products installed by an organization
- Nubuto Cloud can be installed and administered by organizations on their own infrastructure. That organization is responsible for the sites over which it has control. Users of such sites should direct data privacy questions to their administrator, as their use of the Services is subject to that organization’s policies. Dragoman Translation is not responsible for the privacy or security practices of an administrator’s organization, which may be different from this policy.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
- You may contact Dragoman Translation by email at [email protected]
11th May 2018
These terms and conditions were created using a document from Rocket Lawyer (https://www.rocketlawyer.co.uk).