Protecting the personal data of our employees, business partners, and customers is a high priority for Worldwide Interpreters OÜ, hereinafter referred to as ‘We’, ‘Us’ or ‘Our’. This Privacy Policy (hereinafter also ‘Privacy Notice’) includes useful information about how and for what purposes Worldwide Interpreters collects, processes, and shares personal data. Worldwide Interpreters are subject to Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter ‘General Data Protection Regulation’). This Privacy Policy is applicable to all business processes of Worldwide Interpreters as well as to any economic software, websites, mobile phone applications, cloud services, computer software, and so on used by or associated with us (hereinafter all collectively ‘Worldwide Interpreters' 'means of work’). This Privacy Policy includes information about how the we as controllers process data by means and for purposes determined by them as well as about how they, as processors, process personal data under their clients’ instructions.

We process personal data only for the purpose of providing services to our clients and ensuring the proper operation of all the functions of all our means of work.

Privacy policy for personal data processing at Worldwide Interpreters.

1. Data processing subjects

Worldwide Interpreters processes the personal data of its employees, representatives, partners and contact persons of clients and, if necessary, users of tour means of work.

We also process data on behalf of our clients who are controllers. Data subjects whose data is processed by Worldwide Interpreters are also referred to as ‘natural persons’ in this Privacy Notice.

2. Controllers

Worldwide Interpreters determines the purposes, means, and extent of processing of personal data, and is therefore, the controller.

3. Processing of personal data

We only process the personal data of representatives of clients to perform Our contractual obligations and provide high-quality services to Our clients. The legal basis for processing is Our legitimate interest and/or the performance of a contract concluded with a data subject or the taking of pre-contractual measures as requested by a data subject to ensure the proper provision of Our services.

1. We generally collect personal data directly from data subjects, which means representatives of clients, natural persons, and employees of corporate customers who use or intend to use Our and services as well Our employees and partners.
2. Worldwide Interpreters does not process special categories of personal data, such as sensitive personal data.
3. We process the following personal data:
   1. Contact details, including name, address, phone number, IP address, and e-mail address;
   2. Date of birth, age and gender and/or personal identification code, client number;
   3. Employment data, including employer, title, post, and professional preferences;
   4. Financial data;
   5. User operations in connection with e-mails sent to the Sunny Companies and information contained therein and accompanied thereby;
   6. Other personal data which Our current or potential clients have made publicly available

4. Sharing of personal data

1. Outside Worldwide Interpreters
   1. We may share certain categories of personal data with Our business partners if it is necessary for providing Our services, lawful and in compliance with the applicable personal data protection law. In that case, We may share personal data only in connection with providing products or services to Our clients. The legal basis for such processing of personal data is Our legitimate interest.
   2. We share personal data that is required for payment processing, with our authorized data processor.
2. Authorities
   1. In cases provided by law, the police, the Tax Board, and other authorities may require Us to disclose certain categories of personal data. Worldwide Interpreters provide the personal data of natural persons to authorities only in compliance with applicable law. In that case, the legal basis for the processing of personal data is the performance of an obligation arising from the law.

5. Rights of data subjects

1. General rights
   1. Data subjects have the right to request access to, rectification, or erasure of their personal data or restriction of processing and to object to the processing as well as the right to data portability.
      1. The right to rectification means the data subject’s right to the rectification of inaccurate personal data concerning him or her without undue delay.
      2. The right to erasure means the data subject’s right to the erasure of personal data concerning him or her without undue delay, provided certain additional requirements are met.
      3. In certain cases, the data subject has the right to restrict the processing of his or her personal data.
      4. The data subject has the right of access to personal data which We retain concerning him or her and which he or she has provided to Us, and the right to transmit this data to another controller if it is technically feasible and the processing is based on consent or on a contract and carried out by automated means.
      5. The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of his or her personal data which is based on the relevant provisions of law, including profiling based on those provisions.
      6. Unless otherwise provided by law, the data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
      7. Where the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
   2. Data subjects also have the right to lodge a complaint with a supervisory authority.
   3. Should you choose to exercise those rights, We kindly ask you to contact Us at the address info@winterpreters.com

6. Security and retention period of data

1. The secure storage of data is the highest priority for Worldwide Interpreters. We have done everything possible to avoid unauthorized access to and disclosure, loss, or other unlawful processing of data. We protect the confidentiality and integrity of personal data and We ensure access to data in compliance with applicable law. To protect personal data collected and processed by Us, We have taken reasonable and sufficient organizational measures and set technical and physical restrictions. The measures applied to depend on the category of personal data and the possible effects of its disclosure.
2. The storage and retention of all data retained by Worldwide Interpreters (including personal data) take place either in Our own servers and/or under a contract in servers of verified cooperation partners, including Our hosting provider Render (render.com), whose servers may be located in different countries around the world. We and Our cooperation partners have taken high level technical, physical and organizational measures necessary to ensure security.
3. Worldwide Interpreters retain personal data only for as long as necessary to achieve the purpose for which the data was collected. The retention period also depends on the need to reply to data subjects’ inquiries, solve problems and comply with requirements for document retention arising from the law. When We no longer need personal data and the law does not require the retention thereof, We erase the data without delay.

7. Amendements to notice

For the purpose of increasing security or complying with amendments to the law, Worldwide Interpreters may amend or adapt this Privacy Notice at any time. Should We do so, We shall publish the revised Notice here with a new version date. We may notify you of significant changes in Our Privacy Notice and privacy principles before they take effect by way of e-mail, announcement on Our website, and/or on Our social media sites. Nevertheless, please visit this site from time to time to keep up to date with minor changes in the Privacy Notice.

8. Our contact details

We value your feedback, opinions, and suggestions. If you have any problems, comments, or questions, please contact Us at the address info@winterpreters.com. You can also contact Us through regular mail at the address Sepapaja tn 6, 15551 Tallinn, Harju Maakond, Estonia.