Privacy Policy

Introduction

Welcome to Comtec Translations’ privacy policy

Comtec Translations Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Comtec Translations Limited collects and processes your personal data through your use of this website, including any data you may provide through this website or to us when you sign up to receive our newsletter or you engage us to provide our services to you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This privacy policy should be read together with any additional policies we may provide from time to time, including policies relating to our use of Artificial Intelligence (AI), which provide further detail on how we use such technologies.

Controller

Comtec Translations Limited is the controller and responsible for your personal data (referred to as Comtec Translations, we, us or our in this privacy policy).

Our registered office address is: 3 Pegasus House Pegasus Court, Olympus Avenue, Warwick, Warwickshire CV34 6LW

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Email address: IT@comtectranslations.com

Postal address: Comtec Translations Limited, Victoria Court, 8 Dormer Place, Leamington Spa, Warwickshire CV32 5AE

Telephone number: +44 (0) 1926 335 681

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you wish to raise a concern or complaint about how we handle your personal data, please contact IT@comtectranslations.com.

We will acknowledge your complaint, promptly and without unnecessary delay, within 30 days and aim to resolve it within 30 days (60 days total). If we are unable to resolve any complaint within this 60-day timeframe, we will:

keep you informed of progress throughout the process,
explain the reasons for the delay, and
provide a revised timeframe for resolution.

If you are not satisfied with our response, you may escalate your complaint or contact the Information Commissioner’s Office (ICO).

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 25/06/2026.

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

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not intentionally collect Special Categories of Personal Data. However, such data maybe included within content provided to use by clients or otherwise submitted in the course of our services and may be processed where necessary to deliver those services. This may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). This also includes any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- contact us about our services;
- request price information from us about our services;
- order services from us;
- subscribe to our newsletter or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  - analytics providers, such as Google based outside the UK;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

See the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity, Contact	Performance of a contract with you
To provide you with our services:	Identity, Contact, Financial, Transaction, Marketing and Communications	Performance of a contract with you
Manage payments, fees and charges.		Necessary for our legitimate interests (to recover debts due to us)
Collect and recover money owed to us
To manage our relationship with you which will include:	Identity, Contact, Profile, Marketing and Communications	Performance of a contract with you
(a) Notifying you about changes to our terms or privacy policy		Necessary to comply with a legal obligation.
(b) Asking you to leave a review or take a survey		Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a prize draw, competition or complete a survey	Identity, Contact, Profile, Usage, Marketing and Communications	Performance of a contract with you
		Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
	Identity, Contact, Technical	Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Technical, Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	Identity, Contact, Technical, Usage, Profile, Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)
To provide AI-assisted translation, transcription, and language services and to support internal operational efficiency using AI tools	Identity, Contact, Technical, Usage, and Client-provided content	Necessary for the performance of a contract; Legitimate interests (efficient service delivery and business operations)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or you have purchased services from us and you have not opted out of receiving that marketing.

Marketing communications from third parties

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing communications

You can ask us or third parties to stop sending you marketing messages at any time in the following ways:

by following the opt-out links on any marketing message sent to you.
by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of engaging us to provide services, contacting us with queries, or other transactions.

Third Party Service Providers and Processors

Our carefully selected partners and service providers may process personal information on our behalf where necessary to provide and support our services. These may include providers of digital marketing, AI-assisted service delivery tools, analytics, hosting and IT support, billing, invoicing, accounting and payment processing services.

Where a third-party acts as our processor, we put in place appropriate contractual safeguards, including Data Processing Agreements where required, and require them to process personal data only on our documented instructions, apply appropriate security measures and in accordance with applicable data protection law.

A current list of our key sub-processors is available on request by contacting IT@comtectranslations.com

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4A. Artificial Intelligence (AI) and Automated Processing

We use Artificial Intelligence (AI) tools and technologies to support the delivery of our services and our internal operations.

How we use AI

We may use AI-assisted tools to:

provide translation, transcription, subtitling and multilingual services;
support internal business operations, including drafting, communication, summarisation, administrative tasks and sales and marketing support; and
enhance the efficiency and quality of our services.

These tools may process personal data where it is included in:

client-provided content; or
information input by our staff in the course of providing our services.

Human oversight

AI tools are used as a support mechanism only. Outputs generated by AI are subject to review by our personnel before being used or shared externally. We do not rely on AI to make decisions that have legal or similarly significant effects on individuals.

AI service providers

To support these services, we may use approved third-party providers of AI and language technologies. These providers process personal data on our behalf and are contractually required to:

act only on our instructions;
apply appropriate security measures; and
comply with applicable data protection laws.

Where available, we use business-grade AI services configured so that personal data is not used by the provider to train public AI models.

Safeguards

We implement controls designed to protect personal data when using AI, including:

limiting the data that is input into AI tools to what is necessary;
using approved tools subject to internal governance controls;
applying contractual and technical safeguards with our providers; and
maintaining human oversight of outputs.

Special category data

While we do not intentionally collect special categories of personal data, such data may be included in client-provided content and processed as part of delivering our services where necessary.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

External Third Parties as set out in the Glossary.
providers of cloud-based systems, AI technologies, and language processing tools who process personal data on our behalf in connection with the delivery of our services and internal operations;
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we use AI tools as part of service delivery, details of how client data is handled in those tools is set out in our AI Policy statement.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Some of our AI and technology service providers may process personal data outside the UK or European Economic Area. Where this occurs, we ensure appropriate safeguards are in place, such as approved contractual clauses or transfers to jurisdictions recognised as providing an adequate level of protection.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Unsolicited supplier CVs will be kept on file for a maximum of 2 years as we have a legitimate interest to keep this data in accordance with current service requirements

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise
  or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate
  grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.