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Third Country Transfer Policy

In order to translate content into certain languages, it may be necessary to send the files and/or documents provided to us to subcontractors in countries outside the EU/EEA and EU’s list of Adequate Countries, where data protection laws may not be as strong and may not offer the same level of protection. By providing your content to us, you agree to thistransfer,storing or processing.

Article 49 of the GDPR provides for transfers to entities in a country without an adequate level of protection under a series of exceptions. Our basis for such transfers is set out in Article 49(1)(b): “the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre‐contractual measures taken at the data subject’s request”.

The best personnel choice for service provision are those based in the countries in which the languages are spoken as full immersion is most conducive to fluency retention and allows the individualsto remain fully informed regarding changesto language and its use. Furthermore, we are more likely to have available linguists working in their native language in their native country.

If we intend to transfer your information outside the EEA, we will inform you in accordance with Article 49(1)(a) of the GDPR: “The data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards”.

If the files provided to us contain personal data, it is your responsibility to inform the data subject that their data may be transferred outside the EU/EEA and Adequate Countries in order for the contract to be fulfilled, and gain consent for that.

We will take all reasonable steps to ensure this data is transferred safely and securely, and we will only transfer personal data to, or allow access by, subcontractors when it is assured that the information will be processed legitimately and protected appropriately by the recipient.

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