Privacy Policy

Welcome to www.adaptria.com (the “Website”), operated by Locaria Limited (“Locaria”, “we”, “us”, or “our”). We respect your privacy and are committed to safeguarding your personal data. This Privacy Policy explains how we collect, use, store, and otherwise process personal information about visitors to our Website and individuals who interact with us through it.

This Privacy Policy is provided in accordance with the UK General Data Protection Regulation (“UK GDPR”), the EU General Data Protection Regulation (“EU GDPR”), the Data Protection Act 2018, and other applicable data protection laws in the jurisdictions in which we operate. For the purposes of these laws, Locaria Limited is the data controller of your personal data.

Please read this Privacy Policy carefully to understand how and why we process your personal data and your rights in relation to it.

Where we rely on your consent (for example, for certain cookies or marketing communications), we will request it separately, and you may withdraw it at any time. Your use of the Website alone does not constitute consent to the processing of your personal data. If you submit a form via the Website, we will process the information you provide in order to respond to your enquiry, provide requested information, or take steps at your request prior to entering into a contract.

Information about how we use cookies and similar technologies is provided in our Cookie Notice below.

We may collect and process the following categories of personal data:

1. Information you provide directly to us

This includes information you submit when you contact us, complete a form on our Website, request information about our services, subscribe to communications, or apply for a role. This may include your name, company name, job title, email address, telephone number, and any other information you choose to provide in your message or attachments (for example, CVs or application materials).

2. Communications data

Records of correspondence if you contact us, including emails, enquiries, feedback, or other communications you send to us.

3. Technical and usage data

Information about how you use our Website, including IP address, browser type and version, device type, operating system, referring URLs, pages visited, and dates and times of access. This information may be collected through cookies and similar technologies (please see our Cookie Notice for further information).

4. Additional information from our linguists

If you apply to provide your services as a linguist with Locaria, we will collect additional personal information as part of your registration and, if accepted, to manage our working relationship with you.

This may include: your professional profile, assessment/test results, completed projects or work assignments, payment details, and any other information necessary to manage payments and financial records.

We process this information primarily to manage our contractual relationship with you, and additionally for legitimate business purposes such as future communications, quality control, and maintaining records of past projects and linguists.

Locaria uses its internal platform, Adaptria™, to manage the personal information provided by linguists. All data is hosted on Google Cloud Platform servers located within the European Economic Area (“EEA”), and may be accessed only by authorized personnel of Locaria and its affiliates for the purposes described in this Privacy Policy.

Payment processing may be handled by JPMORGAN CHASE BANK, N.A. (London Branch), and PayPal (Europe) S.a.r.l. et Cie, S.C.A. These companies may host your personal data within the EEA or, where necessary, outside the EEA. Where data is transferred outside the EEA, Locaria ensures appropriate safeguards are in place in accordance with applicable data protection laws (e.g., Standard Contractual Clauses).

5. Third-party websites

Our Website may contain links to third-party websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy notices.

6. Your choice

You are not required to provide personal data when browsing our Website. However, if you choose not to provide certain information, we may be unable to respond to your enquiry, provide requested services, or manage a working relationship as a linguist.

Under the UK GDPR, the EU GDPR, and the Data Protection Act 2018, we are required to have a lawful basis to process personal data. We rely on the following:

1. Consent

Where you have given your consent (for example, signing up for newsletters or marketing communications), we process your personal data based on that consent. You may withdraw your consent at any time.

2. Contractual obligations

Where processing is necessary to perform a contract with you (for example, managing linguist assignments, payments, and professional profiles), we rely on this lawful basis.

3. Legal compliance

Where processing is required to comply with a legal obligation (for example, financial record-keeping, tax reporting, or law enforcement requests), we rely on this lawful basis.

4. Legitimate interests

Where processing is necessary for our legitimate business interests (for example, improving our services, contacting potential clients, or maintaining security) and does not override your rights, we rely on this lawful basis.

We process your personal data for the following purposes:

• To respond to requests or enquiries made through the Website.
• To manage the work undertaken by our linguists (assignments, payments, profile management).
• To operate security systems, including CCTV in our offices, for security and safety purposes (based on our legitimate interests). 
• To process payments to linguists and suppliers.
• To contact you about relevant services, events, or updates where you have provided consent.
• To send communications required by law or necessary to inform you of changes to services or policies.
• To improve our Website and services, including testing and analytics.
• To share data with law enforcement if legally required.
• To send surveys or feedback requests to improve our services (non-promotional; legitimate interest).

We use cookies and similar technologies on our Website to ensure that it functions properly, to improve user experience, and to analyse Website usage. Cookies are small text files that are placed on your device when you visit our Website. They enable the Website to recognize your device and store information about your preferences or previous activity. We use the following categories of cookies:  

1. Strictly necessary cookies. These cookies are essential for the operation and security of the Website, enabling core functionality such as page navigation and access to secure areas. These cookies do not require your consent.  
2. Analytical cookies. These cookies help us to understand how visitors interact with our Website, improve its performance and enhance the user experience.  
3. Marketing and tracking cookies. These cookies track visitors across the Website, measure the effectiveness of advertising and display relevant content or advertisements. 

We may use analytics and tracking services provided by third parties, such as Google Analytics and Google Tag Manager, as well as LinkedIn and other similar technologies. These services may collect information such as IP addresses, device identifiers, browser types, pages visited and interactions with the Website. This information may be combined with other information collected by these third parties. We may also embed content from third-party platforms, such as video content or social media features, which may result in those third parties setting cookies. Where such third-party cookies are used, the relevant third parties may act as independent data controllers and process your personal data in accordance with their own privacy policies.    

Some cookies are strictly necessary for the operation and security of the Website and are placed on the basis of our legitimate interests or to provide a service requested by the visitors. Other cookies, such as analytics or marketing cookies, will only be placed on your device with your prior consent.

We may share your personal data with selected third parties where necessary for the purposes described in this Privacy Policy and in accordance with applicable data protection laws. We share personal data with the following categories of recipients:

Service providers and processors

We engage trusted third-party service providers to support our business operations and the delivery of our services. These providers process personal data on our behalf and only in accordance with our instructions. These include:

• cloud hosting and infrastructure providers (including Google Cloud Platform);
• customer relationship management providers (such as Salesforce, etc);
• communication and email distribution providers (such as Brevo or similar services);
• payment and accounting providers (including JP Morgan, PayPal, and other financial service providers);
• IT support and system administration providers.

Our vendor management platform used to manage linguist profiles and projects is owned and operated by Locaria and hosted on secure cloud infrastructure provided by Google Cloud Platform.

Group companies and affiliates

We may share personal data within the Locaria group of companies where necessary for internal administration, service delivery, project management, and reporting purposes.

Professional advisors

We may disclose personal data to our professional advisors where necessary, including lawyers, auditors, accountants, and insurers.

Legal and regulatory authorities 

We may disclose personal data where required to do so by law, regulation, court order, or to protect our legal rights, prevent fraud, or ensure the safety and security of our staff, clients, linguists, and systems.

Security Measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, or damage. These measures include, where appropriate:

• restricted access to personal data on a need-to-know basis;
• secure cloud hosting infrastructure (including Google Cloud Platform);
• password protection and access controls;
• contractual confidentiality obligations for employees and service providers;
• monitoring and security procedures designed to safeguard our systems.

While we take reasonable steps to protect your personal data, please note that transmission of information via the internet is not completely secure. Although we do our best to protect personal data, we cannot guarantee the absolute security of data transmitted to or from our Website. 

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for legal, contractual, and tax obligations. In particular:

• Personal and contact information related to a contractual relationship will generally be retained for up to 12 months after the end of that relationship, unless we have a legitimate reason to keep it longer.
• Records relating to payments, invoices, and tax compliance will be retained for up to 6 years (or longer where required by applicable tax or accounting laws).
• Project records, work submissions, and test results will generally be retained for up to 3 years after the end of the relevant project.

After the retention period ends, personal data will be securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised information may be retained for statistical analysis and business planning purposes.

Some of our service providers and affiliates operate outside the United Kingdom. As a result, personal data may be transferred to countries that do not have the same level of data protection as the UK.

Whenever we transfer personal data outside the UK, we implement appropriate safeguards in accordance with applicable data protection laws. These safeguards may include:

• transfers to countries that have been recognized by the UK Government as providing an adequate level of protection for personal data;  
• the use of appropriate contractual safeguards, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission’s Standard Contractual Clauses (SCCs);
• other safeguards permitted under applicable data protection laws, such as binding corporate rules or specific legal derogations, where appropriate.

We take all reasonable steps to ensure that personal data is processed securely and in accordance with this Privacy Policy, regardless of the country in which it is processed.

Our Website may contain links to websites operated by third parties. We do not control these websites and are not responsible for their content, privacy practices, or how they collect or use your personal data.

We encourage you to review the privacy policies and terms of use of any third-party websites you visit to understand how they handle your information and whether they use cookies or similar technologies.

Our Website may include social media features, such as the X Corp Tweet Button (formerly Twitter), Facebook Like Button, Instragram Like Button, and LinkedIn Share Button. These features are provided by the respective social media platforms and allow you to share content from our Website directly on your social media accounts.

By using these features, you may link your social media profile to our Website and make information about your interactions accessible to the social media platform, in accordance with their privacy policies and terms of use. We do not control how these platforms use your information.

For further details on how your data may be used by these social media platforms, please consult their privacy policies:

• X Corp (Twitter) Privacy Policy
• Facebook Privacy Policy
• Instagram Privacy Policy
• LinkedIn Privacy Policy

Under the EU GDPR and UK GDPR, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Ask us to correct any personal data that is inaccurate, incomplete, or out of date.
• Erasure: Request that we delete your personal data where we no longer need it, or where processing is based on consent and you withdraw that consent.
• Restriction of Processing: Ask us to limit how we use your personal data in certain circumstances, for example, if you contest its accuracy or object to processing.
• Objection: Object to the processing of your personal data for direct marketing, or in cases where processing is based on our legitimate interests.
• Data Portability: Request your personal data in a structured, commonly used, and machine-readable format, and where technically feasible, have it transferred to another controller.
• Withdrawal of Consent: If you have given consent for specific processing (e.g., marketing communications), you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent before it was withdrawn.
• Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where permitted by law.

We do not currently carry out automated decision-making or profiling that produces legal or similarly significant effects. 

To exercise any of your rights, please contact us at: privacy@locaria.com 

We may ask you to verify your identity before processing your request, and if you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission. If we choose not to action your request, we will explain the reasons for our decision.

You have the right to stop the use of your personal data for direct marketing at any time, either through all channels or selected channels. We will always comply with your request.

If you feel that your data has not been handled correctly, or you are unhappy with our response to your request, you have the right to lodge a complaint with the relevant data protection authority:

• UK: Information Commissioner’s Office (ICO)
• Phone: 0303 123 1113
• Online: www.ico.org.uk/concerns

If you are located in the EEA, you also have the right to lodge a complaint with the supervisory authority in the EU Member State of your habitual residence, place of work, or the place of the alleged infringement.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or services. When we make changes, we will post the updated Privacy Policy on our Website, along with the date of the most recent update, so you are aware of what information we collect, how we use it, and under what circumstances we may disclose it.

We encourage you to review this Privacy Policy periodically. Your continued use of the Website after updates indicates that you have been informed of the updated Privacy Policy.  

For the purposes of the UK GDPR, the EU GDPR, and the Data Protection Act 2018, the data controller responsible for your personal data is Locaria Limited, a company incorporated in England with its registered office at:

110 Southwark Street

London SE1 0S

United Kingdom

If you have any questions about this Privacy Policy, or wish to exercise your rights under applicable data protection laws, please contact our Data Protection Officer at:

Data Protection Officer

Locaria Limited

110 Southwark Street

London SE1 0SU

United Kingdom

Email: privacy@locaria.com