Aztec Circle is committed to protecting Client privacy and takes its responsibility regarding the security and protection of Client information very seriously. As a Company we are clear and transparent about the information we collect and what we do with that information.
This policy sets out what data we collect and process about you in connection with your relationship with us as a Client through your use of our website and online services including:
- Where we obtain data from
- What we do with that data
- How we store the data
- Who we disclose that data to and for what reason
- How we deal with your data protection rights
- How we comply with data protection rules
All personal data collected and processed by Aztec Circle is in accordance with UK and EU data protection laws.
Aztec Circle (referred to below as “we”, “us”, “our” or “Aztec Circle”) in this policy refers to the Company Aztec Circle Limited. The “Client”, “Customer” or “you” refers to the company, firm, body, organisation or person contacting Aztec Circle to undertake services on its behalf.
Aztec Circle Limited is the data controller of all personal information that is collected and processed about Aztec Circle Clients for the purposed of the General Data Protection Regulation (GDPR). Aztec Circle is registered Nigeria and registered offices can be found at Block 7, Allen Way, Surulere, Lago, Nigeria.
What personal data we collect
In this instance personal data refers to any information relating to you that allows us to identify you, including your name, contact details, project reference number, payment details used as well as information about your access to our website.
Aztec Circle may collect personal data from you when you arrange a project with us. This includes both projects which have been arranged directly or those that have been arranged indirectly through a third party, the use of our website or when you contact us.
The categories of information that Aztec Circle may collect include the following:
- Your name, job title, business name, business address, Company registration numbers, e-mail address, telephone number, credit/debit card number or other payment details
- Information about your purchases of our products and services
- Information about your use of our website
- The communications you exchange with us through different platforms
Aztec Circle will only process such data in instances when you have given your consent or if you have deliberately made it public.
What do we use personal data for?
Your data may be collected and used for the following purposes:
- To provide products and services you request – we use the information that you give us to complete the services you have asked for in relation to your project, including any requested project changes
- To contact you in the event of a time change in the delivery of our services, to inform you of the services that you have requested and any other changes that may be needed to complete the service
- Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and/or prevent any fraudulent activities
- Customer services communications: we use your data to manage our relationship with you as our Customer and to improve our services
- Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during and after the delivery of our services as well as to personalise the services that we can offer to you
- Marketing: occasionally we may contact you with information regarding promotions and offers via e-mail. You will have the choice to opt in or out of this service by indicating your preference at our project booking stage. You will also be given the opportunity to opt out of future marketing communications using a link provided in the emails that we send you to indicate that you no longer wish to receive marketing material
We only process your personal data in instances where we have a legal basis to do so. The legal basis depends on the reasons we have collected and need to use your personal data for.
Aztec Circle may also process your data for one of the following reasons:
- To comply with a legal obligation
- You have consented to us using your personal data (for example for marketing related purposes)
- To protect your vital interests or those of another person
- When it is in our legitimate interest in operating a translation services business
We will not retain your data for any longer than is necessary to fulfil the purpose that it has been collected for. In order to determine the appropriate retention period of your data we will consider the amount, nature and sensitivity of the personal data being processed, the purposes for which we process the data and whether we can achieve those purposes through any other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations, or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of personal data
Aztec Circle follows strict security procedures in the storage and disclosure of your personal data. The data that you provide is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the internet.
All payment details collected by the Company are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
International data transfer
Aztec Circle operates businesses in multiple jurisdictions, some of which are not located in the European Economic Area (EEA), such the USA. While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with UK and EU law on data protection. We utilise standard means under EU law to legitimise data transfers outside the EEA.
Sharing your personal data
- Government authorities, law enforcement bodies and regulators in compliance with legal requirements
- Partner companies and freelancers required to deliver the services you have asked for
- Trusted freelancers we are using to run our business such as call centres providing assistance to our Customers, cloud service and e-mail marketing service providers assisting our marketing team with running Customer surveys and providing targeted marketing campaigns
- Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and project booking to process payment or ensure the security of your payment transaction
- Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you
Cookies and site tracking
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. This enables us to better understand the products and services that will be most suitable to you.
A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your service booking.
Most web browsers automatically accept cookies, but you can change these browser settings by accepting, rejecting and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
We use tracking software to monitor Customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal Client information.
Data protection officer
Aztec Circle has an appointed Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority. The Information Commissioner is the lead data protection supervisory authority for Aztec Circle.
Your data protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, contact our DPO by post at Aztec Circle Data Protection Officer:
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.