This sets out the privacy statement of Columbus 7 BV, based at Minervalaan 42/II, 1077 PB, Amsterdam. We explain how Columbus 7 uses personal data when you apply for a job, when we provide translation services, when you act as a supplier to Columbus 7 and when we use contact data in our CRM system. If you have questions about how Columbus 7 uses your data, please contact us at firstname.lastname@example.org. This privacy statement dates from 1 August 2020 and may change.
Columbus 7 is the sole controller when you visit our websites, when we handle job applications, when we use contact data in our CRM system, and when you provide us with goods or services.
However, Columbus 7 often considers itself to share responsibility as controller with the client when we provide translation services. We normally agree with the client that Columbus 7 and the client can each deal with requests from individuals exercising their privacy rights. In certain exceptional cases the client is the sole controller and Columbus 7 is the processor. If we are the processor, and you contact us with a privacy-related question, we will refer you to the organisation that is the controller.
Columbus 7 has one website: www.columbus7.com.
Here we collect usage data: your IP address, the pages you visit, when you visit those pages, and (where applicable) the previous/subsequent site you visit. We use this data for various reasons, including: to generate usage statistics; to provide for (additional) functionality on the sites; to manage the sites by resolving any technical faults or improving accessibility to certain parts of the sites; and safeguarding the security of our IT systems. We retain this data for 12 days, unless stated otherwise. We process this data to ensure that you can visit a functional and secure websites and apps. We use an external hosting provider to serve the websites and apps, except for ECC, which we host ourselves. This means that for those websites where we use a hosting provider, the personal data collected when you visit our website will be transferred to the hosting provider (as a processor).
When you visit a website of Columbus 7, cookies are placed on your computer. Columbus 7 uses two types of cookies:
When you apply for a job at Columbus 7, you will need to provide certain personal information. If you provide us with a link to your LinkedIn profile, we will also add the profile information to your application. You may be asked to provide further information in follow-up correspondence with us.
We use this data: to assess your suitability for the position, to safeguard our internal control and security, to comply with legal obligations, and to handle requests for reimbursement of your expenses. We also use the information to determine your employment terms. We process this data to ensure that we find suitable candidates for our vacancies, or – in the case of identity documents and certificates of conduct – because we have a legal obligation to do so.
If you have applied to work at Columbus 7 and you have been hired, the data will be added to your employee file and retained for seven years after you leave Columbus 7. If you have been accepted to one of our student events, the data will be stored for two years. If your application has been rejected, the data will be retained for a period of four weeks after our decision, unless you give us permission to use your personal data to inform you of any suitable vacancy or position in the near future. In that case, we will retain your data for one year.
Columbus 7 is generally engaged for Dutch-English translation services provided to leading law firms and their clients. In the course of providing those services, we process personal data of different categories of people. These include clients, clients’ contact persons, witnesses, experts, counterparties, counterparties’ contact persons, counterparties’ lawyers and advisors, and persons whose personal data forms part of a file. In particular:
- When translating advisory, litigation, curial and arbitral materials and when, for the purpose of providing translations, performing investigations (for suitable terminology, for example), we may search for relevant information in files provided by our clients or another party and use this information in the translations we provide.
We also process some of the personal data mentioned above for internal knowhow purposes. For example, we store relevant files (after attempting to remove most personal data) and some of our interactions with others, such as, representatives of supervisory authorities, lawyers and judges, in our internal knowhow repository, to retrieve this information at a later date.
We do this processing on the basis of our clients’ legitimate interest in receiving high quality translations as well as on our interest in providing high quality translations.
We will also use the contact details (name, address, email address) of our client (or their contact person) to send invoices. We do this to enable us to collect fees for our services, as part of the performance of the agreement between us and our client.
We retain our files for 20 years after the matter is closed, unless we are required by law to retain the files for a longer period of no more than 30 years (for example, in certain environmental cases). After this period, you may ask us to return original documents provided by the client, and we will securely destroy all files.
Prior to most engagements, we may collect certain information to verify the identity of the client. Columbus 7 retains this information for a period of five years after the termination of the relationship or the performance of the transaction.
When you or your employer does business with us, we will collect certain data about you. Often this information, such as your name, email address and position, is provided by yourself in the course of doing business with us. Part of it might be derived from the order documents: we register what services or goods are provided, and payment details. And, sometimes, we will ask for other information, such as a certificate of conduct. If you are a freelancer, we will also store the contract we have with you. We use this information to process and handle incoming invoices, to book invoices on matters in order to bill these to clients, to create a balance sheet and an overview of profits and losses, to file tax returns, to create internal financial reports, and to arrange for an audit by an accountant.
The basis for the handling of invoices is the performance of our contract with you, or because we have a legitimate interest in performing the contract with your employer. The basis for booking the incoming invoices to clients is the interest in charging our clients for the services provided. The basis for creating a balance sheet and an overview of profits and losses, and to create internal reports on finances, is because we are legally obliged to do so and because we have an interest in administering our finances. The filing of tax claims and the performing of an audit by account is done because we are legally obliged to do so. We retain invoices we receive and the contracts with suppliers, including contact details of suppliers, for a minimum of seven years.
Columbus 7 uses a company-wide system to keep track of its contacts. For most persons, we store the name, email address, phone number, job title and work history (e.g., for which organisation did someone work or is now working). We sometimes also store additional information about someone, such as the industry he or she works in, gender, mailing language, areas of interest, home address, birthday, spouse/partner’s name, hobbies, and other personal notes. We also keep track of the mailings we send to this person. If, in the past, you have been a client of Columbus 7, were subscribed to our newsletters, or have worked with Columbus 7, your records are probably in this system.
We use this data to address you personally and ensure that persons within the firm communicating with you know your relevant personal details. We also use this data to get a better overview of your network, the company you work for and its market(s).
Columbus 7 takes office-wide security measures as part of its information security framework. Technical measures include the use of access controls, firewalls, network segmentation, virus scanners, traffic monitoring, penetration tests, and encryption of laptops, phones and USB-sticks. Organisational measures include a clear screen policy, confidentiality provisions, privacy and security training and awareness, and implementing controls in contracts with suppliers.
Columbus 7 ensures that it provides appropriate safeguards for such a transfer in accordance with the GDPR.
While this is unlikely, we may be required to disclose personal data by a court order or to comply with other legal or regulatory requirements. We will do everything we reasonably can to notify the persons involved before we disclose these data, unless we are legally restricted from doing so.
You are entitled at any time to request inspection, correction, removal or restriction of the processing of your personal data by Columbus 7. The request should be addressed to email@example.com. You may also lodge a complaint with the Dutch data protection authority.