This Privacy Notice is provided by Iceni Technology Limited (‘we‘ or ‘us‘). We are a ‘controller’ for the purposes “Data Protection Laws” that applies to us in the UK. We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.
If you have any questions about this Privacy Notice, how we handle your personal data, or would like to exercise any of your rights, please contact:
|Address||36 St. Faiths Lane, Norwich, England, NR1 1NN|
The latest version of the Privacy Notice can be found here on our website
We may change this Privacy Notice from time to time. Please
visit our website from time to time to see any such changes.
Current version: 7 July 2021
We have listed below certain words and phrases that have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice:
|Controller||This means any person who determines the purposes for which, and the manner in which, any personal data is processed. In this case we are the controller.|
|Data Protection Laws||This means the laws which govern the handling of personal data. This includes the General Data Protection Regulation (EU) 2016/679, the Data Protection Act 2018 in force in the UK, and further laws and statutory instruments relating to such regulations from time to time.|
|Data Subject||This means the person to whom the personal data relates.|
|Data Protection Regulator||The supervisory authority overseeing compliance with the Data Protection Laws. In the UK, this means the UK Information Commissioner’s Office (“ICO“), which is responsible for implementing, overseeing and enforcing the Data Protection Laws in the UK.|
|Personal Data||This means any information from which a living individual can be identified. This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs and voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions). It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.|
|Processing||This covers virtually anything anyone can do with personal data, including:
|Special Categories of Personal Data||This means any information relating to:
We may collect, use, store and transfer different kinds of personal data about you which we have been provided with as follows:
We do not share any of this information with any other parties unless we are obliged to do so by law.
We do not share any of this information with any other parties. License owners have access to all of this information via the on-line license management service.
We implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.
We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (please see section ‘How is processing your data lawful‘ for further detail):
|Type of data||Why do we need it?||Lawful basis for processing|
|License Records||To track when you purchased a license and its current validity as well as the number of
users to which it applies (multi-user licenses).
Visit https://www.iceni.com/user_license_login.htm to view your license records.
|To comply with the software licensing agreement we have in place with you and because it is in our legitimate interests.|
|Activation Records||To monitor the number of activations (installations) made with a specific license. This
helps us to stop users making multiple activations with only a single-user license for
Visit https://www.iceni.com/user_license_login.htm to manage your machine activation records.
|We have a legitimate interest in ensuring that licences are used within the agreed scope of the services.|
|User Records||The TransPDF user record helps to identify a user when logging-in to the TransPDF
Your ‘My Account’ page contains a “Delete Account’ button which will remove all your data from the system within 24 hours.
|To provide you with the services you request and because it is in our legitimate interests.|
Name of the original document, source and destination languages.
|This data is helpful when estimating throughput, diagnosing problems with the translation process as well as assisting with the calculation of usage charges. Once the PDF has been removed from the system, this data has no direct link to a user or any original PDF. The PDF name is the only connection to the original translation request.||It is in our legitimate interest to use this data to ensure the quality of our services.|
|Credit Records||We use this to record chargeable usage of the system. When a refund is requested by a user, this data is needed to identify and verify the specific translation request relevant to the refund. We also use this data to provide monthly and annual usage summaries to users as displayed in their ‘My Account’ page on the TransPDF website.||To provide you with the services you request and because it is in our legitimate interests.|
|Cat Tool Usage||We use this data to estimate the popularity of the specific CAT tool integrations we support. Anonymised usage data for a specific tool can be seen by some of the CAT tool vendors we work with.||We have a legitimate interest in using this data to inform and/or improve our services.|
|Email address, first, last name||When you purchase a license for Infix PDF Editor or sign-up to use TransPDF your name
and email address are stored in a mailing list hosted by
The mailing list is used to send announcements of technical & feature upgrades to the relevant product or service. It is also used to inform of the availability of new ‘how-to’ guides related to TransPDF or Infix PDF Editor when we deem that it may be relevant to your purchase/enrolment.
Every email contains highly visible opt-out links which will remove you from the mailing list as well as an explanation from as to why you are receiving the email.
|We have a legitimate interest in informing you of technical changes to the services you should be aware of, and offering you upgrades and other services similar than what you use.|
We are allowed to process your personal data based on the following legal bases for the purposes explained in this Website Privacy Notice:
You can object to processing that we carry out on the grounds of legitimate interests. See the section headed “Your Rights” to find out how.
We use processors to support our IT systems and operate our website, such as web hosting providers, internal technology providers such as our CRM system, helpdesk system, and IT support providers. Some of these service providers will process your data as part of the services they offer to us. For example, if you choose to use the automatic translation facility, the text content from your PDF is sent to Microsoft Azure Text Translator in USA for translation. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure. If you would like to know the names of our service providers, please contact us (see section “How to Contact Us“).
Your personal data is transferred outside of the UK and the EEA in order for our web hosting and CRM system providers which are located in the US, to provide services to us. Any transfer of your data outside the UK and the EEA will be carried out in accordance with the law to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms.
We only retain your personal data for as long as we need it to provide you with the services or as required by law. Unless we are required by law to retain your personal data for a longer period, the following categories of personal data will be kept for the following periods and will be securely deleted/ destroyed after the expiry of the retention period:
|Data we process||How long this will be held for|
|Infix License record, Activation record||Until you ask for it to be removed.|
|TransPDF user record, CAT tool usage records, Credit charge records||Until you ask for your TransPDF account to be removed from the system|
|Email address, first & last name||Until you unsubscribe from our mailing list using one of the unsubscribe links in the last email your received.|
License and activation information, as well as all TransPDF user data is stored in a Postgress SQL database in London, UK on a computer hosted by Amazon Web Services..
Use of the auto-translation facility causes your PDF to be uploaded to one of our TransPDF servers in Ireland hosted by Amazon Web Services.
There it is stripped of its text and that text is sent to Microsoft Azure Text Translator in USA for translation.
The PDF and its translation remains on the TransPDF server for up to 30 days after which time it is purged.
As a European data subject, you have the following legal rights under the Data Protection Laws in relation to your personal data. You can exercise these rights free of charge, by contacting us (please see “How to contact us“). We will respond to any rights that you exercise within a month of receiving the request unless the request is particularly complex, in which case we will respond within three months.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Please be aware that there are exceptions and exemptions that apply to some of these rights, which we will apply in accordance with the Data Protection Laws.
|Your data protection rights||What does this mean?|
|1||Right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and what your rights are. This is why we are providing you this Privacy Notice.|
|2||Right of access||
You have the right to obtain access to your personal data we process and certain other information (similar to that provided in this Privacy Notice).
This is so you are aware and can check that we are using your information in accordance with Data Protection Laws.
You may ask for:
To help us find the information, please give us as much information as possible about the type of personal data you would like to see.
|3||Right to rectification||You are entitled to have your information corrected if it is inaccurate or incomplete. If you would like us to do this, please contact us (see section “How to Contact Us“).|
|4||Rights to ask us to stop contact you with direct marketing||You can ask us to stop contacting you for direct marketing purposes. If you would like to do so, please contact us. Alternatively, you can also click the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 7 days for this to take place.|
|5||Rights in relation to automated decision making||These rights are not applicable as we do not carry out any automated decision making.|
|6||Right to erasure||This is also known as the ‘right to be forgotten’ and, in simple terms, enables you to
request the deletion or removal of your information where:
|7||Right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing
is restricted we can still store your information, but may not use it further. You may
request that we stop processing your personal data temporarily if:
|8||Right to data portability||You have rights in certain circumstances to obtain and reuse your personal data for your own purposes across different services.|
|9||Right to object to processing||You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing.|
|10||Right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the
right to withdraw your consent at any time (although if you do so, that does not mean
anything we have done with your personal data with your consent up to that point is
Please contact us if you wish to withdraw your consent to anything we do with your personal data.
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
It is important that you ensure you have read this Privacy Notice. If you do not think that we have processed your data in accordance with this Privacy Notice, you should let us know as soon as possible. You also have the right to complain to the Data Protection Regulator located in your country. Information about how to do this is available on each Data Protection Regulator's website.
In the UK, this is the Information Commissioner's Office.