PRIVACY POLICY

DUNA TRANSLATIONS

In compliance with the legal duty of information established in Article 13 of Regulation (EU) 2016/679, they are provided with the following basic information regarding the personal data provided:

Información básica sobre Protección de Datos
Data controller

Manuel Dueñas

Calle Madre Carmen Salles 2
San Lorenzo de El Escorial
28200 Madrid, España

Email:  manuelduenas@dunatranslations.com                        

Purposes of treatment 1.- Translation and localization services: IT localization; websites and software; on demand translation; Technical translation, Life sciences, medical devices and pharmaceuticals.
2.- Automated translation solutions: Evaluation of automatic translation; Edition of automatic translation (edition, PE); Verification of source content; Integration of existing content.
QA and other linguistic services: Third Party Linguistic QA; Provider Evaluation; International SEO and SEM Services; Pre-editing.
Creation of different mercantile documents, such as, budgets, information forms, order sheets, invoices, etc.
Legitimation of treatment Consent of the person concerned  
Recipients of the data No data will be transferred to third parties, except for legal obligations.
Rights Access, rectify and delete the data, as well as other rights, as notified in the additional information.
Provenance From the owner.
Data protection controller (DPD) Data Protection Controller: manuelduenas@dunatranslations.com

By means of this Privacy Policy, DUNA TRANSLATIONS aims to show its commitment to compliance with regulations and legislation deriving from the processing of information necessary for the provision of its services, and the use of Information and Communication Technologies. In particular, DUNA TRANSLATIONS declares its commitment to complying with regulations for the protection of personal data. In this sense, the following are considered as a frame of reference, mainly:

  • – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD)
  • – Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights
  • – Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI)

This statement applies to any website, application, product, software or service owned by or linked to DUNA TRANSLATIONS (collectively, our “Services”). Occasionally, a service may be linked to a separate privacy statement, which will list the particular privacy practices of that service.

This policy may be periodically updated. In the event that we make changes that we deem important, we will inform you through a notice in the relevant services or we will communicate with you through other means such as email.

1. ABOUT US (CONTROLLER)

DUNA TRANSLATIONS, owner of the web domain, and responsible for the processing of information is a limited company, registered in the Mercantile Register with registered address for this purpose in

Calle Madre Carmen Salles 2
San Lorenzo de El Escorial
28200 Madrid, España

In general, DUNA TRANSLATIONS provides the following contact e-mail address: manuelduenas@dunatranslations.com

The address indicated shall be the address for notification, communication and contact purposes. In addition, DUNA TRANSLATIONS has provided the following e-mail address for communications and notifications relating to the processing of information and personal data, including the exercise of the rights indicated in this Policy: manuelduenas@dunatranslations.com

2. PERSONAL INFORMATION AND DATA WE COLLECT (PURPOSE)

Personal information refers to any information that relates to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, especially with reference to an identifying element, whether it be a name, an identification number, location data, online identification, or one or more factors specific to that person’s physical, psychological, economic, cultural, academic or social identity.

DUNA TRANSLATIONS collects, stores and treats information necessary for the provision of our services is of a medical nature. Although most of this information is of a business nature, it may include personal data, mainly relating to contact personnel or representatives of our client companies, and may include: identifying and contact information, academic and professional information, and economic information and bank data, marital status, health, necessary for the provision, management and billing of our services and for our operational and business purposes.

As a consequence of the provision of these services, and for their adequate development, DUNA TRANSLATIONS may have access to information and personal data contained in the files of our client companies. In these cases, DUNA TRANSLATIONS shall assume the role of TREATMENT CONFIDENTIAL, undertaking to maintain the confidentiality and security of said data, as well as to treat the data exclusively for the purposes defined by the Data Controller (client). In these cases, and in compliance with data protection regulations, DUNA TRANSLATIONS will include, in the corresponding contracts with our clients, the clauses necessary to ensure compliance with the requirements of the regulations.

On the other hand, and in any case with the express request and authorisation of the interested party, DUNA TRANSLATIONS may use the contact details of our clients, potential clients or other users who request it, to send communications referring to our products or services, as well as any other information that we understand may be of interest to them.

In addition, through our website, we have various forms through which users can contact us or request specific information about our products or services. In any case, the necessary contact and identification data will be requested in order to process your request. In the same way, the DUNA TRANSLATIONS website may be used to advertise various events to which users may register, requesting in such cases the identification and contact details necessary to process the registration and management or attendance of the event.

On the other hand, internally. DUNA TRANSLATIONS collects, stores and processes the personal data of its employees and collaborators, which are necessary to maintain the working relationship with them, and, in particular, to fulfil purposes such as the preparation of payrolls, personnel management, occupational risk prevention, compliance with tax and social security obligations, professional training and development, time or holiday management. For these purposes, DUNA TRANSLATIONS shall collect, throughout the employment relationship, all the necessary personal data (identification and contact data, academic and professional data, banking data and billing data), and may include data which by their nature imply a special level of protection (such as trade union membership or workers’ health data), only within the margins authorised by the applicable legislation. Within this treatment, personal data obtained through resumes or job applications that are sent through the corresponding forms on our website, or in person, are also considered. In general, this information (which may include, mainly, identification and contact data, and academic and professional data) is kept only for the time necessary to process your application.

In addition, our servers, logs, and other technologies may automatically collect certain information to help us administer, protect, and improve our services, analyze their use, and improve the user experience. In this sense, we may consider the cookies used while users are browsing our web services, which are dealt with in detail in point 10 of this Policy, or the IP addresses, on which it is worth pointing out the following: an IP address is a number automatically assigned to a computer when it connects to the Internet, and which may allow the identification of a physical person (considered to be personal data). In certain cases, and only when necessary (such as in the case of online contracting, or in order to obtain only statistical measurements that allow us to know the number of visits made to the web services, the order of visits, the access point, etc.), through the web services of DUNA TRANSLATIONS the IP address used by the user can be detected. The processing of this data will also be subject to the aforementioned considerations regarding the protection of personal data.

3. HOW WE PROTECT PERSONAL INFORMATION AND DATA

At DUNA TRANSLATIONS we are highly committed to the security of the information we handle, and to complying with the legal requirements that apply to us. In this sense, to ensure the confidentiality, availability and integrity of both the information we handle (and, in particular, personal data), as well as the systems, networks, applications and databases used for processing, RM-TRANSLATION AND EDITING SL.:

We carry out periodic assessments of the risks associated with information security and the protection of personal data, analysing our situation with regard to risk and defining action plans accordingly.

An Information Security and Data Protection Policy has been defined which must be complied with by the different parties involved in the processing of information.

Procedures have been developed for Access Control, System and Communication Security, Incident Management and Security Violations, and Information Backup.

Awareness raising and training actions have been developed to ensure compliance with these policies and procedures.

In addition, both workers and collaborators, service providers or any other natural or legal person who may have access to our information, we require you to be committed to maintaining confidentiality of the data and information to which you access, and may take the necessary legal action in the event of non-compliance with these commitments.

In the event that, as a user or affected party, you detect any incident or breach of security, or any vulnerability that may be affected, DUNA TRANSLATIONS makes the following address available to those affected: manuelduenas@dunatranslations.com, through which communications can be made that are considered appropriate or necessary for the improvement of the security of our information and systems.

4. DERECHOS DE LOS TITULARES DE LOS DATOS

DUNA TRANSLATIONS has provided the necessary means to comply with the right to information and to obtain consent in the cases necessary to ensure the lawfulness of the processing of personal data. When obtaining or collecting information, DUNA TRANSLATIONS undertakes to inform those affected about the identity of the person responsible, the purpose, possible communications or transfers, and the possibility of exercising the rights set out in the regulations.

DUNA TRANSLATIONS also acknowledges and guarantees the possibility of exercising the rights of access, rectification, cancellation, opposition, limitation of processing and portability, collected by data protection regulations. As affected user, you can request:

ACCESS RIGHT: Obtain confirmation of whether your data are being processed and if so, you have the right to access the following information regarding the processing of your data:

  • – the purposes of the treatment;
  • – the categories of personal data concerned;
  • – the recipients or categories of recipients to whom the personal data may be disclosed;
  • – the time limit for the storage of personal data
  • – the existence of the right to request rectification, erasure, opposition to data, or limitation of processing
  • – the right to lodge a complaint with a supervisory authority;
  • – where personal data have not been obtained from the data subject, any available information on their origin, the existence of automated decisions, including profiling and meaningful information on the logic applied, as well as the anticipated importance and consequences of such processing for the data subject.
  • – When personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards under Article 46 concerning the transfer.
  • RIGHT OF SUPRESSION: Obtain the deletion of your data when any of the following circumstances occur (provided that the data do not comply with any of the requirements contemplated in the regulations: that they are data of general interest, necessary for compliance with a legal obligation, or to exercise the right to freedom of expression):
  • – the personal data are no longer necessary for the purpose for which they were collected
  • – the data subject withdraws the consent given for the processing of the data;
  • – the data subject objects to the processing and other legitimate grounds for the processing do not prevail
  • – the personal data have been processed unlawfully;
  • – the personal data must be deleted in order to comply with a legal obligation that may be laid down;

RIGHT OF RECTIFICATION: Modify inaccurate, erroneous or incomplete data.

PORTABILITY RIGHT: To receive from DUNA TRANSLATIONS the personal data concerning him/her and to transmit them to another controller when:

– the lawfulness of the processing is based on the consent of the data subject or on the fulfilment of a contract

– the processing is carried out by automated means.

OPPOSITION RIGHT: To oppose the processing of personal data concerning him/her based on the fulfilment of purposes of public interest, or of legitimate interest for the data controller.

TREATMENT LIMITATION RIGHT: To obtain from the data controller the limitation of data processing when one of the following conditions is met:

– the interested party challenges the accuracy of the personal data, during a period that allows the person in charge to verify the accuracy of them;

– the processing is illegal, and the data subject opposes the deletion of personal data and requests instead the limitation of its use;

– the controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the formulation, exercise or defense of claims;

– the data subject has objected to the processing by virtue of the right of objection

In order to exercise these rights, DUNA TRANSLATIONS has set up an e-mail address: manuelduenas@dunatranslations.com through which you can contact the organization to request the exercise of the rights recognized by the regulations. In the same way, these can be exercised through the postal address indicated in the first section

Calle Madre Carmen Salles 2
San Lorenzo de El Escorial
28200 Madrid, España

For a proper exercise of these rights, we urge you to use as a reference the templates and models for the exercise of rights that can be located on the website of the Data Protection Agency (www.agpd.es), or that you can request through the means of contact indicated (in particular, through email manuelduenas@dunatranslations.com).

In addition, we inform you of the possibility, in the event of considering that your rights have been violated, or that no adequate action has been taken with regard to the requests for rights that you may have made, of presenting the corresponding claim before the Data Protection Agency, and you may address the same through the electronic headquarters accessible from its web page (www.agpd.es).

5. WHAT INFORMATION WE COMMUNICATE OR TRANSFER

DUNA TRANSLATIONS does not communicate personal data to third parties beyond those communications necessary for the provision of services or arising from legal requirements that apply to us. In particular, the personal data collected may be communicated, BY LEGAL OBLIGATION, and according to their specific competence, to public administrations, for the performance of their institutional functions, to banking entities, to subjects specializing in the management of information systems and/or payment systems, to subjects providing goods or services offered by DUNA TRANSLATIONS, to subjects that RM-TRANSLATION AND EDITING S.L uses for promotional, advertising, marketing and communication activities, to insurance and financial companies, to law firms and consultants, to subjects in charge of accounting or auditing RM-TRANSLATION AND EDITING S.L, and to public authorities for compliance with the law.

Under no circumstances will DUNA TRANSLATIONS disseminate personal data.

On the other hand, at DUNA TRANSLATIONS we establish agreements, alliances or collaborations with other entities that provide us with certain services or that collaborate in the development of certain activities, being able to have access to the personal data that we manage. In addition, we have certain subcontracted services in which we rely for the provision and development of our services. This is mainly the case of external hosting services (housing) or web hosting, or the service for sending our Newsletter.

In order to provide these services, the corresponding external treatment contracts have been signed, ensuring compliance with the requirements of the regulations. In cases where these services are provided or require the intervention of entities or systems hosted in third countries, DUNA TRANSLATIONS ensures that, in cases requiring international data transfers, these are made to countries that demonstrate a level of security comparable to that of European regulations. In this sense, the adequacy decisions of the European Data Protection Committee, or, in its absence, certificates, corporate rules, contractual clauses or any other recognized mechanism that accredits an adequate level of protection, will be considered.

6. HOW LONG DO WE KEEP THE INFORMATION?

As a general rule, at DUNA TRANSLATIONS we only keep information and personal data for the time necessary to comply with the purpose for which the data was obtained, as well as to deal with any possible claims or responsibilities that may arise as a result of the processing of the data. As a general rule, once the service has been provided, the data is blocked and no processing is carried out on them other than to keep them at the disposal of the Public Administrations, Judges and Courts, in order to attend to the possible responsibilities arising from the processing, during the period of prescription of these, after which they must be deleted. On the other hand, in order to determine data retention periods, DUNA TRANSLATIONS considers local laws, contractual obligations and the expectations and requirements of our clients. In particular, at DUNA TRANSLATIONS we keep the data relating to the invoicing of our services, as well as the information derived from our training services for a period of 5 years, in compliance with current legislation. In general, at DUNA TRANSLATIONS we understand this adequate period of time, and we extend it to the appropriate period of time for the attention of the possible responsibilities arising from the treatment. In cases in which these obligations or conservation needs do not apply, or in the case of treatments in which the consideration of responsibilities derived from the treatment is not necessary, DUNA TRANSLATIONS proceeds to the suppression of the data after the time necessary to guarantee the adequate fulfillment of the purpose for which they were obtained (in no case a term of more than one year after the provision of the requested service).

7. INTELLECTUAL AND INDUSTRIAL PROPERTY

The content of DUNA TRANSLATIONS services and websites, including their structure, design, texts, source code, as well as the logos, trademarks and other distinctive signs appearing therein, are the property of DUNA TRANSLATIONS or its collaborators or associated third parties, and are protected by the corresponding intellectual and industrial property rights. Likewise, the images, videos, sounds, audios and other graphic elements contained in the portals are protected by the corresponding rights.

Therefore, by virtue of the provisions of Articles 8 and 32.1 of the Law on Intellectual Property, it is expressly prohibited to copy, reproduce, publish or alter any content of the websites of DUNA TRANSLATIONS without the prior authorization of the same. DUNA TRANSLATIONS authorizes the total or partial reproduction of the texts and contents provided by the portal, provided that the following conditions are met:

– The integrity of the contents, documents or graphics is maintained.

– DUNA TRANSLATIONS is expressly cited as their source and origin.

– The purpose and purpose of such use is compatible with the activity of DUNA TRANSLATIONS

– Commercial use is not intended and distribution, public communication or transformation is expressly prohibited.

The User undertakes to respect the Intellectual and Industrial Property rights owned by DUNA TRANSLATIONS You may view the elements of the portal and even print them, copy them and store them on the hard disk of your computer or on any other physical support provided that it is solely and exclusively for your personal and private use. The User shall refrain from deleting, altering, evading or manipulating any protection device or security system installed on the pages of DUNA TRANSLATIONS

8. GENERAL CONDITIONS OF USE AND LIABILITY

The websites of DUNA TRANSLATIONS aim to provide the general public with knowledge of the activities carried out by this company and the products and services it provides, as well as offering the possibility of contracting certain services. Similarly, the partial or total provision of certain services contracted by customers is permitted.

The use of any of these Web sites implies the express and full acceptance of the conditions herein, without prejudice to those individuals that may apply to some of the specific services offered through the site.

In order to keep the information published in the portals up to date, the contents thereof may be modified, corrected, deleted or added at any time, so it will be convenient to check the validity or accuracy of the same by going to official sources. Likewise, this privacy policy may be subject to change, correction or modification, in order to keep it adequate to the needs of the organization, as well as to current regulations.

a. Responsibility for the operation of the Web

DUNA TRANSLATIONS cannot guarantee the absence of errors in access to the Web services or in their content, although DUNA TRANSLATIONS will develop the necessary mechanisms to reduce these scenarios and correct and update them as quickly as possible.

Likewise, DUNA TRANSLATIONS cannot be held responsible for possible errors, interferences or interruptions of the service that may derive from causes such as computer viruses, telephone or network breakdowns, disconnections and other types of failures caused by causes beyond the control of the owner of the Web.

DUNA TRANSLATIONS reserves the right to temporarily suspend the operation of the web services at any time, whenever necessary for maintenance, repair, updating or improvement tasks. Likewise, DUNA TRANSLATIONS reserves the right to deny or withdraw access to the portal and/or the services offered without prior notice, at its own request or at the request of a third party, to those users who do not comply with these General Conditions of Use.

On the other hand, DUNA TRANSLATIONS is not responsible for the contents that may be published by users or by any third party through the forums, comments or social networks associated with the websites, although DUNA TRANSLATIONS will provide the necessary means to remove this type of content and to guarantee compliance with applicable legislation, as well as respect for the rights of those affected and public order. In the event that users detect any content that affects in this sense, it is recommended that they contact DUNA TRANSLATIONS as quickly as possible, through the means provided.

b. Responsibility for links

The links contained in our web services may lead to external web services managed by third parties in order to provide the user with access to information or related resources. DUNA TRANSLATIONS does not manage, review, nor can it be held responsible for the contents, functioning or information of the websites to which it directs, with which no relationship is maintained. DUNA TRANSLATIONS cannot be held responsible for any damages that may arise from these linked pages. Likewise, the inclusion of these external connections does not imply any type of association, merger or participation with the connected entities.

c. Responsibility of users

The User guarantees that the Personal Data provided to DUNA TRANSLATIONS (where necessary) are true and is responsible for communicating any changes in them. The user will be solely responsible for any damage or injury, direct or indirect, that may cause to responsible file or any third party because of the completion of the forms with false, inaccurate, incomplete or outdated data.

The User undertakes to use the website, content and services in accordance with the Law, this Legal Notice, good customs and public order. Similarly, the User undertakes not to use the website or the services provided through it for purposes contrary to the content of this Legal Notice, or for purposes that are unlawful or harmful to the interests and/or rights of third parties, such as: disseminating content or propaganda of a racist, xenophobic, pornographic-illegal, advocacy of terrorism or attacking human rights; causing damage to the physical and logical systems of RM-TRANSLATION AND EDITING SL, of its suppliers or third parties; introduce or disseminate on the network computer viruses or any other physical or logical systems that are likely to cause the aforementioned damage; attempt to access and, where appropriate, use the accounts of other users and modify or manipulate their message. The User expressly undertakes not to destroy, alter, render useless or, in any other way, damage the data, programs or electronic documents and others found on this Website, as well as not to hinder their proper functioning.

Likewise, the User undertakes not to hinder the access of other users to the service by means of the massive consumption of the computer resources through which the holder of the Web provides the service, as well as to carry out actions that damage, interrupt or generate errors in these systems. The User undertakes not to introduce programs, viruses, macros, applets, ActiveX controls or any other logical device or sequence of characters that may cause errors on the website.

9. APPLICABLE LAW AND JURISDICTION

These General Conditions are governed by Spanish law. The parties submit, at their option, for the resolution of conflicts and waiving any other jurisdiction, to the courts and tribunals of the user’s domicile. Also, as an entity adhered to Confianza Online and under the terms of its Code of Ethics, in case of disputes relating to online recruitment and advertising, data protection and protection of minors, the user may resort to the system of extrajudicial resolution of disputes Confianza Online (www.confianzaonline.es).

Link to the online dispute resolution platform (ODR): https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home.show&lng=ES

10. COOKIE POLICY

The web services provided by DUNA TRANSLATIONS may use cookies when a user navigates the site. Cookies are files sent to the browser by means of a web server in order to record the activities of the user during their time of navigation. The cookies used by the website are only associated with an anonymous user and his computer, and do not themselves provide the user’s personal data. Through the use of cookies, it is possible for the server where the website is located to recognize the web browser used by the user in order to make browsing easier, allowing, for example, access to users who have previously registered, access to areas, services, promotions or competitions reserved exclusively for them without having to register on each visit. They are also used to measure audience and traffic parameters, monitor progress and number of entries.

The user has the ability to configure your browser to be warned of the receipt of cookies and to prevent their installation on your computer. Please refer to your browser’s instructions and manuals for more information. To use the website, it is not necessary that the user allows the installation of cookies sent by the site, or the third party acting on its behalf, notwithstanding that it is necessary for the user to log in as such in each of the services whose provision requires prior registration or ‘login’. The cookies used on this website are, in any case, temporary in nature with the sole purpose of making their subsequent transmission more efficient. Under no circumstances will cookies be used to collect personal information. In particular, the types of cookies used by the services of DUNA TRANSLATIONS include:

Addthis: Complementary cookies for exchanging social and advertising content. The AddThis service allows you to share content through social networks such as Facebook or Twitter, email or other media. AddThis also uses cookies to collect anonymous information for advertising purposes.

Google Analytics: Google Analytics is the analysis tool that helps website and application owners understand how visitors interact with their properties. This tool may use a set of cookies to collect information and provide statistics of website usage without personally identifying Google visitors. The main cookie used by Google Analytics is “__ga”. In addition to providing website usage statistics, Google Analytics may also be used in conjunction with some of the advertising cookies described above to display more relevant ads on Google’s properties (e.g., on Google’s search engine) and throughout the web.

Vimeo: Appear on pages that use Vimeo videos and are used by Vimeo to provide video viewing services. Sendinblue: Cookies related to our relational marketing service. They are used when accessing DUNA TRANSLATIONS web services through newsletter links.

Furthermore, the user is informed that DUNA TRANSLATIONS web services may be used to access other external services managed by third parties and not managed by DUNA TRANSLATIONS (Twitter, Youtube,…) in which cookies can be used, being advisable for the user to verify in each case the Policy on the use of the same.

  • a. Acceptance of Cookie Policy
  • DUNA TRANSLATIONS displays information about its Cookies Policy at the bottom of any portal page with each login so that you are aware.
  • Given this information it is possible to carry out the following actions:
  • – Accept cookies. This notice will not be displayed again when you access any page of the portal during this session.
  • – Modify the configuration. You may obtain more information on what cookies are, learn about DUNA TRANSLATIONS Cookie Policy and modify your browser settings to restrict or block DUNA TRANSLATIONS cookies at any time. In the case of restricting or blocking cookies, the functions of the website may be reduced.
  • – Continue browsing or move around the scroll bar: in which case we consider that you accept its use.

b. How to modify cookie settings

You can restrict, block or delete cookies from any website, using your browser. In each browser the operation is different, the ‘Help’ function will show you how to do it. Here are the links to the support services of different web browser providers, which indicate how to delete, enable and manage cookies:

Internet Explorer: windows.microsoft.com/es-xl/internet-explorer/delete-manage-cookies#ie=”ie-10″

FireFox: support.mozilla.org/es/kb/Borrar%20cookies

Chrome: support.google.com/chrome/answer/95647?hl=”es”

Safari: www.apple.com/es/privacy/use-of-cookies/

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