Privacy Policy

1. Collection and storage of personal data and the nature and purpose of its use

a) When visiting the website

When you access our website www.lexeri.com, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a log file. The following information is collected without your intervention and stored until automatic erasure:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Website from which you accessed our site (referrer URL)
  • Browser, operating system of your computer and name of your access provider

We process this data for the following purposes:

  • to ensure smooth connection to the website
  • to ensure our website’s ease of use
  • to evaluate system security and stability and
  • for further administrative purposes.

The legal basis for data processing is Art. 6 (1) 1 point f) GDPR. Our legitimate interest is based on the data collection purposes listed above. Under no circumstances will we use the collected data to draw any conclusions about you as an individual. We also use cookies and analysis services when you visit our website. Further details can be found under nos. 4 and 5 of this Privacy Policy.

b) Newsletter

If you register for our newsletter, we will use the data required for this purpose and provided by you to send you our email newsletter regularly on the basis of your consent in accordance with Art. 6 para. 1 point a) GDPR.

Content of the newsletter: The contents of the newsletter are described in more detail during the registration process. In addition, our newsletter contains information about our products, offers, promotions and our company.

Registration procedure: The double opt-in procedure is used to register for our newsletter. After registration, we will send you an email in which we ask you to confirm your registration to receive our newsletter. This is the only way to exclude unauthorised registration through the misappropriation of email addresses. We store the time of registration and confirmation as well as the IP address in order to prove that you registered for our newsletter. Simply providing your email address is sufficient in order to register for our newsletter. You provide your name on a voluntary basis and only so that we can address you personally in the newsletter.

Newsletter success measurement: Newsletters that you have agreed to receive contain a web beacon, i.e. a pixel-sized file that is retrieved from the server of our delivery service provider when the newsletter is opened. Due to this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour in their access locations (which can be determined by means of the IP address) or access times. Statistical information is also collected on whether and when newsletters are opened and which links are clicked on. Technical measures enable the assignment of this information to the individual newsletter recipients. However, we use the analysis exclusively to identify the reading habits of our users and to adapt our content to their needs or to send different content based on the interests of our users.

Legal basis: Sending the newsletter and success measurements are is based on your consent in accordance with Art. 6 para. 1 point a), Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 Act Against Unfair Competition (UWG). Logging of the registration process is carried out in accordance with Art. 6 para. 1 point f) GDPR and our legitimate interest in using a secure newsletter system that serves both our business interests and your expectations and allows us to prove consent.

Logout/withdrawal: Cancellation of the newsletter – and therefore withdrawal of your consent – is possible at any time. You can unsubscribe either by sending a message to the contact details provided above or by using the link included at the end of each newsletter. After you unsubscribe, we may store your email address and the data from the registration process for up to three years. The basis for this is our legitimate interest in proving that prior consent was obtained. The processing of this data is limited to the purpose of defending claims. Individual erasure is possible upon request, provided the lawfulness of prior consent is confirmed at the same time.

Dispatch service provider: The dispatch of our newsletter is carried out by the external service provider Mailchimp (The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000 Atlanta, Georgia 30308, USA). Mailchimp is certified under the Privacy Shield Agreement, which guarantees compliance with European data protection laws: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active

c) Email advertising without registering for the newsletter and your right to object

If we receive your email address in connection with the sale of a product or service and you have not objected to this, we reserve the right, on the basis of Section 7 para. 3 UWG, to send you regular emails with offers of other products and services that are similar to those that you already use. This takes place to protect our legitimate interests, which override the legitimate interests of our clients, to send them marketing materials in accordance with Art. 6 para. 1 point f) GDPR.

You can object to this use of your email address at any time by sending a message to the contact address stated at the beginning of this policy or by selecting the link provided for this purpose in the advertising email. You will not incur any costs other than the transmission costs according to the basic rates.

d) Postal advertising and your right to object

We reserve the right to use your first and last name as well as your postal address, which we have received from you in connection with the sale of goods or services, for our own marketing purposes, e.g. to send you offers and information about our products by post. This takes place to protect our legitimate interests, which override the legitimate interests of our clients, to send them marketing materials in accordance with Art. 6 para. 1 s. 1 point f) GDPR.

e) Orders/jobs

We collect and process the following data within the scope of orders/jobs, which is necessary for the mutual and proper performance of the contract. This includes:

  • first name and surname
  • billing address, street, postcode and city
  • phone number
  • email address
  • company name
  • EU tax identification number
  • data for payment processing
  • product interests
  • communication history
  • previous enquiries and orders
  • creditworthiness information
  • texts for translation

Data is processed for the purpose of orders/job on the basis of your voluntarily consent in accordance with Art. 6 (1) 1 point a) GDPR as well as for the performance of the contract in accordance with Art. 6 (1) 1 point b) GDPR. The data is erased at the latest after expiry of legal warranty and comparable obligations (e.g. texts to be translated) or, where legal archiving obligations apply, after their expiry (e.g. inventory data, communication history).

Data transferred to us for the initiation of measures prior to entering into a contract will be processed in accordance with Art. 6 para. 1 s. 1 point a) GDPR on the basis of your voluntary consent and in accordance with Art. 6 para. 1 s. 1 point b) GDPR. The data will be erased when it is clear that an order will not be placed, but after one year at the latest.

(f) Translation

The texts transferred to us by the customer are stored by us and made available to the translator. Depending on the source and/or target language, a transfer to freelance service providers for performance of the contract takes place on the basis of Art. 6 para. 1 sentence 1 point b) GDPR or within the framework of a data processing agreement pursuant to Art. 28 GDPR. Unless otherwise agreed, this may also include external service providers and may also involve service providers based in third countries outside the EU or in the USA. The requirements of Art. 44 et seq. GDPR for processing in third countries are complied with (adequate level of protection by creating appropriate safeguards such as EU standard contractual clauses, EU-US Privacy Shield). After completion of the order, these documents will be stored for no longer than until the expiry of all claims pursuant to limitation periods for statutory warranty claims. If no order is placed, the source texts will be erased no later than one year after their transfer to us.

g) Credit checks

When paying on account, Toptranslation commissions credit rating agencies to perform identity and credit checks:

  • Creditsafe Deutschland GmbH, Schreiberhauer Strasse 30, 10317 Berlin
  • BFS finance GmbH, Gütersloher Strasse 123, 33415 Verl.

We transfer your name and contact details to these companies for this purpose. The legal basis for the transfer and processing of your data is our legitimate interest in credit security due to our obligation to make advance payments in accordance with Art. 6 para. 1 point f) GDPR.

Information acc. to Art. 14 GDPR concerning the data processing carried out at Creditsafe Deutschland GmbH is available here: https://www.creditsafe.com/de/de/rechtliches/datenschutzhinweise/datenschutzhinweise-fuer-auskunfteidaten.html

We implement adequate measures to protect your rights and freedoms and your legitimate interests. You can object to decisions made using the contact details provided above and inform us of your point of view.

After complete performance of the contract, the data concerning you that has been processed for this purpose will be erased or blocked for further processing, insofar as the statutory storage obligations prevent its erasure.

(h) Payment

The personal data provided by you is transferred to the respective payment provider for the purpose of payment. The scope of the transfer depends on the selected payment method. In the case of a SEPA transfer, your data will not be forwarded to third parties. In the case of transfers via Paypal (PayPal (Europe) S.à rl et Cie, SCA, 22–24 Boulevard Royal, L-2449 Luxembourg) or Skrill (Skrill Limited, 25 Canada Square, London E14 5LQ, United Kingdom), your invoice number, invoice amount and the project details relating to your order will be forwarded to Paypal or Skrill. The extent to which your personal data is used depends on the privacy policy of the respective provider. Data processing is carried out in accordance with Art. 6 para. 1 s. 1 point b) GDPR for the purpose of performing the contract.

(i) Assignment of the claims

Unless otherwise agreed, we assign receivables to BFS finance GmbH (Gütersloher Strasse 123, 33415 Verl) within the scope of our factoring. For the purpose of contractual performance in accordance with Art. 6 para. 1 point b) GDPR and on the basis of our legitimate interest in refinancing and the protection of our legal claims in accordance with Art. 6 para. 1 point f) GDPR, we transfer the following necessary contract details for further collection of the claim:

  • address and contact data
  • language combination of the translation
  • title of the original document
  • number of words, lines or hours
  • payment period
  • telephone and fax number
  • language
  • tax number.

j) Transfer of data to third parties

We will not process and transfer your personal data to third parties for purposes other than those listed above, unless

  • disclosure pursuant to Art. 6 (1) 1 point f) GDPR is required to enforce, exercise or defend legal claims and there is no reason to assume that you have an overriding legitimate interest in non-disclosure of your data;
  • disclosure is legally required pursuant to Art. 6 (1) 1 point c) GDPR.

2. Applicants and application process

We collect and process personal data in accordance with Art. 6 para. 1 point b) GDPR in order to manage the application procedure. If a contract of employment is concluded with an applicant, the transferred data will be stored for the purpose of the employment relationship in compliance with the statutory requirements. If no employment contract is concluded, the application documents will be erased six months after their receipt, unless otherwise agreed, and when they are no longer required for performance of the contract or for steps prior to entering into a contract.

3. Cookies

We use cookies on our website. Cookies are small files that are created automatically by your browser and then placed on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not harm your device and do not contain viruses, Trojans or other malware. Information is stored in the cookie that relates to the specific device used. However, this does not mean that we become directly aware of your identity. Cookies are used to make the use of our service more pleasant for you. For example, we use session cookies to recognise that you have already visited individual pages of our website. They are deleted automatically when you leave our website. We also use temporary cookies stored on your device for a specified period to improve usability. If you visit our website in the future to use our services, the cookie will automatically recognise that you have already visited. It will also recognise your entries and settings so that you do not need to re-enter them. We also use cookies to record statistics about the use of our website and evaluate it for the purpose of optimising our services (see para. 5). These cookies allow us to automatically recognise that you have visited us before when you use our website in the future. These cookies are automatically deleted after a defined period. The data is processed by cookies as required for the purposes mentioned above in order to safeguard our legitimate interests and those of third parties pursuant to Art. 6 (1) 1 point f) GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so that you are alerted before a new cookie is placed. Please note that you may be unable to use all functions of our website if you disable cookies completely. Additional information is available on the website of the Federal Office for Information Security: https://www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrowser/Sicherheitsmassnahmen/Cookies/cookies_node.html

4. Analysis tools

The tracking measures listed below and used by us are based on Art. 6 (1) 1 point f) GDPR. We use these tracking measures for the needs-based design and continuous optimisation of our website. We also use the tracking measures to statistically record the use of our website and evaluate it for the purpose of optimising our services for you. These interests should be considered legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories are as listed for the individual tracking tools.

a) Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as “Google”), for the needs-based design and continuous optimisation of our pages. Pseudonymised usage profiles are created and cookies are used (see para. 4) within this context. The information generated by the cookie about your use of this website, such as:

  • browser type/version
  • operating system used
  • referrer URL (the most recently visited page)
  • host name of the accessing computer (IP address)
  • time of the server request.

may be transferred to a Google server in the USA and stored there. This information is used to evaluate the use of the website, compile reports about website activities and provide further services related to website and Internet usage for the purpose of market research and the needs-based design of this website. Google may also transfer this information to third parties if this is required by law or if such third parties are commissioned to process the information. Your IP address will not be associated with any other data held by Google under any circumstances. The IP addresses are anonymised and cannot be used for identification (IP masking). You can prevent storage of cookies by making appropriate changes to your browser settings; in this case, however, please note that you might not be able to fully use all functions offered by this website.

In addition, you can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=de. As an alternative to the browser add-on, particularly for browsers on mobile devices, you can also prevent the collection of data by Google Analytics by clicking here: http://www.youronlinechoices.com/en/praferenzmanagement/. This will create an opt-out cookie which prevents the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will need to place the opt-out cookie again. Additional information about data privacy in relation to Google Analytics is available at the Google Analytics Help Center: https://support.google.com/analytics/answer/6004245?hl=en

b) Error tracking

If an error occurs while using our systems, our system sends data about the error to third parties. The systems used by these suppliers help us to identify and track technical problems relating to our systems. For this purpose, the following data, among others, is sent to third parties for error tracking:

  • browser type/version
  • operating system used
  • referrer URL (the most recently visited page)
  • URL of the request
  • host name of the accessing computer (IP address)
  • time of the server request.

We use the following third-party providers for error tracking:

  • AppSignal B.V., Rietwaard 4, 5236 WC 's-Hertogenbosch, Netherlands, contact@appsignal.com
  • Rollbar Inc., 51 Federal Street, Suite 401, San Francisco, USA, privacy@rollbar.com

c) Hotjar

We use Hotjar for the needs-based design and continuous optimisation of our pages. Hotjar uses cookies and other technologies to collect information about user behaviour and their devices (the IP address of the device – which is collected and stored in an anonymised form only – as well as screen size, device type (unique device identifiers), browser information and location (only the country)). This information is stored in a pseudonymised user profile. The information is neither used by Hotjar nor Toptranslation to identify individual users nor is it associated with other data about individual users. The data is erased after one year at the latest. The legal basis is Art. 6 para. 1 sentence 1 point a GDPR.

For more information about data protection in connection with Hotjar, visit: https://www.hotjar.com/legal/policies/privacy

5. Tracking and retargeting

Among other things, we use cookies in our systems to monitor our advertising campaigns and for retargeting purposes, i.e. to display advertisements for similar products on third-party websites. The measures listed below are implemented by us on the basis of Art. 6 (1) 1 point f) GDPR. We use these tracking measures for the needs-based design and continuous optimisation of our website and for campaigns. The respective data processing purposes and data categories are as listed for the individual tracking tools.

(a) Google Adwords

Our website uses marketing and retargeting services by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; "Google"). These services enable the more purposeful display of advertising campaigns.

Google code is used and cookies are stored for this purpose when the website is viewed. Alternatively, Google can also use comparable technologies. These cookies allow Google to analyse which websites users have visited and which products they are interested in. Information such as the browser type, operating system and the time spent on the website may also be analysed. All user data is processed pseudonymously. The data is collected by Google and transferred, among other things, to servers in the USA.

When the cookies are created by Google AdWords, Adwords customers receive information such as the number of clicks on the advertising campaigns in order to determine the conversion rate for individual advertising campaigns.

For more information about Google's data usage for marketing purposes, please visit https://www.google.com/policies/technologies/ads and read Google's privacy policy at https://www.google.com/policies/privacy. If you wish to opt out of interest-based advertising through Google Marketing Services, you can change the settings provided by Google at http://www.google.com/ads/preferences.

The legal basis for the use of this service is Art. 6 (1) s. 1 letter f) GDPR.

Google is certified under the Privacy Shield Agreement and therefore guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

(b) Microsoft Bing Ads

We use Microsoft Corporation's marketing and conversion tracking tools (One Microsoft Way, Redmond, WA 98052-6399, USA) on our website. These services enable the more purposeful display of advertising campaigns.

Services code is used and cookies are stored for this purpose when the website is viewed. Alternatively, comparable technologies can also be used. These cookies allow Microsoft to analyse which websites users have visited and which products they are interested in. Information such as the browser type, operating system and the time spent on the website may also be collected. No IP addresses or other personal data is transferred. The data is collected by Microsoft and transferred, among other things, to servers in the USA.

When the cookies are created, we receive information such as the number of clicks on the advertising campaigns in order to determine the conversion rate for individual Bing ad campaigns.

For more information about Microsoft's use of data, visit https://privacy.microsoft.com/en-us/privacystatement.

The legal basis for the use of this service is Art. 6 (1) s. 1 letter f) GDPR.

Microsoft is certified under the Privacy Shield Agreement and therefore guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

6. Social media platforms

We maintain online presences and company sites in social networks and on social platforms in order to be able to communicate with you effectively and to advertise our offers and services.

The social platforms process your data for advertising purposes and create profiles based on your usage behaviour. These usage profiles are used to display ads that are tailored to your presumed interests within and outside of these social platforms. For this purpose, cookies are stored on your computer in which your usage behaviour and interests are recorded.

The processing of your personal data is based on our legitimate interests in effective information and communication with active customers, interested parties and users on social platforms in accordance with Art. 6 para. 1 point f) GDPR. In the event that individual platforms request your consent to data processing (i.e. if you give your consent, e.g. by ticking a check box or clicking on a button), the legal basis for the processing is Art. 6 para. 1 letter a), Art. 7 GDPR.

Your data may be processed outside the territory of the European Union. Platforms whose providers are certified according to the EU-US Privacy Shield guarantee compliance with EU data protection standards.

The most effective way to exercise your rights as a data subject is by contacting the individual provider directly. Only the provider can directly access and delete your data or provide information. You may also contact us for assistance.

A detailed description of each case of processing and the possibilities to object (opt-out) are available on the pages linked below:

Social media platform Facebook Operation of our Facebook page https://www.facebook.com/toptranslation/ is carried out jointly with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), on the basis of an agreement on joint processing of personal data (https://www.facebook.com/legal/terms/page_controller_addendum), privacy policy of the provider Facebook: https://www.facebook.com/about/privacy/ Privacy policy especially for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, possibility to object/opt out: https://www.facebook.com/settings?tab=ads

Privacy Shield (to guarantee an equivalent level of data protection during data processing: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

Social network Twitter: We maintain a page on the Twitter platform at https://twitter.com/toptranslation. Operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Statement: https://twitter.com/de/privacy, (Settings) https://twitter.com/personalization; Privacy Shield (to guarantee an equivalent level of data protection during data processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

Social network Xing: The following applies to our site on the Xing platform at https://www.xing.de The website is operated by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Social Network LinkedIn: The following applies to our site on the LinkedIn platform: The operator is: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy statement: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (to guarantee an equivalent level of data protection during data processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

7. Rights of the data subject

You have the right:

  • to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purpose of processing, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned storage period, the right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origins of your data if not collected by us and the existence of automated decision-making including profiling and, where appropriate, meaningful information about its results
  • to obtain without undue delay the correction of incorrect or complete personal data stored by us in accordance with Art. 16 GDPR
  • to obtain, in accordance with Art. 17 GDPR, the erasure of your personal data we store, except in cases where processing is necessary to exercise the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims
  • to obtain the restriction of processing of your personal data if you contest the accuracy of the data, if the processing is unlawful but you reject their erasure and we no longer need the data, but you require this data for the establishment, exercise or defence of legal claims, or you have objected to the processing of the data according to Art. 21 GDPR
  • to receive your personal data provided to us in a structured, commonly-used and machine-readable format or to request the transfer of the data to another controller in accordance with Art. 20 GDPR
  • to withdraw your consent previously granted to us at any time in accordance with Art. 7 (3) GDPR. As a result, we will no longer be permitted to process the data on the basis of this consent, effective for the future, and
  • to lodge a complaint with a supervisory authority in accordance with Art 77 GDPR. As a rule, you may contact the supervisory authority at your habitual place of residence or work or our company domicile.

8. Right to object

If your personal data is processed on the basis of consent or legitimate interests in accordance with Art. 6 (1) 1 point f) GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR. If you wish to exercise your right of withdrawal or objection, please send an email to privacy@toptranslation.com.

9. Data security

We use TLS technology when you visit our website. In general, this involves 256-bit encryption. We also implement appropriate technical and organisational security measures to protect your data against accidental and intentional manipulation, partial or total loss, destruction and unauthorised access by third parties. Our security measures are constantly improved in line with the latest developments in technology.

10. Updates and amendments to this Privacy Policy

This Privacy Policy is currently valid and is dated May 2018. It may be necessary to change this Privacy Policy to reflect the ongoing development of our website and its services or due to changes in legal or official requirements. The most recent Privacy Policy can be accessed and printed out at any time on the website at www.lexeri.com/rechtliches/datenschutzerklaerung.


Name and contact details of the controller and the company's data protection officer

This data protection information applies to the data processing by:

Toptranslation GmbH
Ferdinandstr. 29–33
20095 Hamburg

Phone: +49 40-609464160
Email: privacy@toptranslation.com
Website: www.toptranslation.com

Our data protection officer is:

Viola Flatau
Lawyer
Rosenhagenstrasse 40
22607 Hamburg

Email: privacy@toptranslation.com

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