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Data Protection

Last updated: 21 October 2026

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1. Data Controller

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The protection of your personal data and the confidential handling of documents entrusted to me are of particular importance to me.

This Privacy Policy provides information pursuant to Articles 13 and 14 of the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter referred to as the "GDPR") concerning the processing of personal data in connection with the use of my website and the translation, interpreting, editing and proofreading services I provide.

Data Controller:

Agnieszka Birsak, MA
Riglergasse 5/10
1180 Wien
Austria

Telephone: +43 660 6953453
Email: birsaktranslations@gmail.com

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2. Categories and Scope of Personal Data Processed

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Depending on how you contact me and the nature of the services commissioned, I may process the following categories of personal data in particular:

  • first and last names, postal addresses and contact details;

  • billing and payment information and, where applicable, business information;

  • information relating to enquiries, quotations, assignments and existing business relationships;

  • personal data contained in documents and other materials submitted to me for processing;

  • personal data that comes to my attention in the course of interpreting assignments or other professional activities;

  • technical data generated when you use my website or electronic means of communication.

Depending on the nature of an assignment, documents provided to me may also contain special categories of personal data within the meaning of Article 9 GDPR, particularly health data, as well as personal data relating to criminal convictions and offences within the meaning of Article 10 GDPR.

I process such data only in accordance with the applicable legal requirements and in compliance with my professional duties of confidentiality.

Where personal data has not been obtained directly from the individual concerned, its source may include, in particular, documents and information provided by Clients. In such cases, I also take into account the information obligations under Article 14 GDPR and the exceptions provided for therein.

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3. Purposes and Legal Bases of Processing

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I process personal data in particular for the following purposes and on the following legal bases:

a) Handling Enquiries and Performing Contracts

If you contact me by telephone, email or through the contact form on my website, I process the personal data you provide in order to respond to your enquiry, prepare a quotation and, where applicable, carry out your assignment.

Where the processing concerns personal data relating to a party to a contract and is necessary to take steps at that person's request before entering into the contract or to perform the contract, the legal basis is Article 6(1)(b) GDPR.

b) Compliance with Legal Obligations

Where processing is necessary to comply with statutory obligations, particularly those arising under tax law, business law or other applicable legislation, the legal basis is Article 6(1)(c) GDPR.

c) Pursuit of Legitimate Interests

Personal data may also be processed on the basis of Article 6(1)(f) GDPR, particularly for the purposes of maintaining proper business administration, ensuring IT security, handling professional enquiries and establishing, exercising or defending legal claims.

This may also apply to certain instances of processing third-party personal data contained in documents submitted for translation, provided that the requirements for relying on this legal basis are met.

This legal basis applies only where the legitimate interests pursued are not overridden by the interests or fundamental rights and freedoms of the individuals concerned.

d) Consent

Where a particular processing activity requires separate consent, processing shall be based on consent that is freely given, specific, informed and unambiguous, in accordance with Article 6(1)(a) GDPR.

Where special categories of personal data are concerned, the additional requirements of Article 9 GDPR must be observed. Where consent under Article 9(2)(a) GDPR is relied upon, such consent must be explicit.

Consent may be withdrawn at any time with effect for the future. Withdrawal shall not affect the lawfulness of processing carried out before the withdrawal.

e) Special Categories of Personal Data and Data Relating to Criminal Offences

The processing of special categories of personal data requires both an appropriate legal basis under Article 6 GDPR and the satisfaction of at least one of the conditions specified in Article 9(2) GDPR.

Personal data relating to criminal convictions and offences is additionally subject to the specific requirements of Article 10 GDPR and applicable national legislation.

Consent given by the person commissioning a service does not automatically provide a sufficient legal basis for processing personal data relating to other individuals.

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4. Use of Artificial Intelligence (AI) and Digital Tools

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I may use digital tools and artificial intelligence (AI) applications to support my professional activities.

Such tools may be used in particular for terminology research, linguistic analysis, the development of suggested wording, language review, quality assurance and assistance with translation, editing and proofreading processes.

The use of these tools is subject to applicable data protection legislation and my professional duties of confidentiality.

The following principles apply:

Professional Responsibility

I remain fully responsible for the services I provide. AI-generated results are subject to appropriate linguistic and professional review, depending on the nature of the assignment. AI systems do not replace my independent professional judgement or responsibility.

Confidentiality and Anonymisation

Information that does not contain personal data, as well as genuinely anonymised information, may be used in AI applications where legally permissible.

Removing names or other direct identifiers does not necessarily constitute effective anonymisation. If an individual can still be identified from the remaining information, the relevant data protection requirements continue to apply.

Processing of Personal Data by External AI Providers

Personal data contained in assignment materials shall be disclosed to external AI service providers only where an appropriate legal basis exists, the necessary data protection and contractual requirements have been met, and no conflicting confidentiality obligations prevent such disclosure.

Depending on the circumstances, this may require a data processing agreement, verification of the provider's data processing and storage conditions, and the implementation of additional security measures.

Particularly Sensitive Documents

Documents containing special categories of personal data, data relating to criminal convictions and offences, or other particularly confidential information may be disclosed to external AI systems only after a separate assessment of whether such processing is legally permissible.

Where explicit consent from the individual concerned is required, it shall be obtained before processing begins. Where third-party personal data is involved, the applicable legal requirements must also be satisfied in respect of those individuals.

No Unauthorised Use of Personal Data for AI Model Training

Confidential assignment documents and personal data shall not be made available for the general training or further development of external AI models without an appropriate legal basis and the necessary authorisations.

Only suitably selected and configured services providing the required level of data protection may be used to process Clients' personal data.

No Solely Automated Decision-Making

I do not subject individuals to decisions based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.

5. Recipients of Personal Data and Data Processors

Personal data may be disclosed to third parties only where such disclosure is necessary for the performance of an assignment and is supported by an appropriate legal basis, is required by law or is covered by valid consent.

Potential recipients include, in particular:

  • providers of website hosting, email services, IT infrastructure and data storage;

  • appropriately qualified language professionals, where their involvement is legally and contractually permissible;

  • providers of digital tools and AI applications, where their use in the particular circumstances complies with applicable data protection legislation;

  • tax advisers, accounting service providers and payment service providers, to the extent necessary;

  • courts, public authorities and other legally authorised bodies, where there is an appropriate obligation or legal authorisation to disclose the data.

I use Gmail for email communication.

Where a service provider acts as a processor within the meaning of Article 28 GDPR, the provider shall be engaged in accordance with the requirements of that provision, including the conclusion of an appropriate data processing agreement.

Any persons engaged by me in connection with assignments who have access to confidential information shall be bound by confidentiality obligations to the extent required.

I do not disclose personal data to third parties for their own marketing purposes without an appropriate legal basis.

 

6. Website, Hosting and Cookies

 

My website has been created and is operated using the Wix platform.

Website Service Provider:

Wix.com Ltd., Israel, together with the relevant affiliated companies and subprocessors involved in providing the services.

When you visit my website, technical data necessary for its operation may be processed, including in particular:

  • IP address;

  • date and time of access;

  • pages accessed;

  • browser and device information;

  • technical connection data.

This information may be processed to ensure the proper operation, security and technical availability of my website.

Where personal data is processed, the legal basis is, in particular, Article 6(1)(f) GDPR, provided that the conditions for relying on this legal basis are met.

Cookies and Similar Technologies

My website may use cookies and similar technologies to store information on users' devices or access information stored on those devices.

Under Section 165(3) of the Austrian Telecommunications Act 2021 [Telekommunikationsgesetz 2021 – TKG 2021], technologies that are not strictly necessary to provide a service expressly requested by the user generally require prior consent.

Technologies that are strictly necessary for the operation of the website may be used without separate consent to the extent permitted by law.

Non-essential cookies and similar technologies may be used only after valid consent has been obtained.

Consent may be withdrawn at any time with effect for the future.

7. Transfers of Personal Data to Third Countries

When certain IT, hosting, communication or other external services are used, personal data may be processed outside the European Economic Area (EEA).

Transfers of personal data to third countries shall take place only in accordance with the requirements of Articles 44 et seq. GDPR.

Depending on the circumstances, transfers may be based in particular on an adequacy decision adopted by the European Commission or appropriate safeguards, such as standard contractual clauses, supplemented by additional protective measures where necessary.

Wix – Israel

As part of the use of the Wix platform, personal data relating to website visitors may be processed by Wix.com Ltd., which is established in Israel.

An adequacy decision of the European Commission applies to transfers of personal data to Israel within the scope of that decision.

Wix group companies and its subprocessors may also process data in other countries. The applicable transfer mechanisms and safeguards must be assessed separately for such transfers.

8. Data Retention and Deletion

As a general rule, I retain personal data only for as long as necessary to fulfil the purposes for which it was collected or is otherwise processed.

Enquiries and Quotations

Where no contract is concluded, enquiry and quotation data shall be deleted once their continued retention is no longer necessary, unless a legitimate legal basis or statutory obligation justifies further retention.

Completed Assignments

Personal data relating to completed assignments shall be retained for as long as necessary to settle contractual matters, comply with statutory obligations and establish, exercise or defend legal claims.

Under Section 132 of the Austrian Federal Fiscal Code [Bundesabgabenordnung – BAO], accounting records, books and related supporting documents are generally subject to a seven-year retention period, calculated in accordance with the provisions of that Act. Longer retention periods may apply in certain circumstances, particularly where records remain relevant to pending proceedings.

Assignment Documents

Source documents, working files, translations and other confidential assignment materials shall be deleted or destroyed once their continued retention is no longer necessary or legally justified, subject to any statutory obligations and applicable professional requirements.

 

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9. Data Security and Confidentiality

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I implement appropriate technical and organisational measures designed to protect personal data, particularly against unauthorised access, loss, unlawful disclosure and other unlawful processing.

Depending on the processing activity, these measures include appropriate access restrictions, secure electronic storage systems, backups and measures for the secure transmission of confidential documents.

Confidential information obtained in the course of my professional activities is handled in accordance with the applicable statutory and professional duties of confidentiality.

Communication by ordinary email may involve residual risks depending on the technical systems used. Separate secure methods of transmission may be agreed for particularly confidential documents.

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10. Provision of Personal Data

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The provision of personal data is generally voluntary unless required by law.

However, certain information, particularly contact details and documents or information necessary for the respective assignment, is required to take steps prior to entering into a contract or to perform the contract.

Failure to provide the necessary data may prevent me from preparing a quotation or carrying out an assignment.

Where assignment materials contain personal data relating to third parties, their disclosure and subsequent processing must meet the applicable legal requirements.

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11. Your Rights

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Subject to the applicable statutory conditions and limitations, you have the following rights in relation to your personal data:

  • right of access (Article 15 GDPR);

  • right to rectification (Article 16 GDPR);

  • right to erasure (Article 17 GDPR);

  • right to restriction of processing (Article 18 GDPR);

  • right to data portability (Article 20 GDPR);

  • right to object to certain processing activities (Article 21 GDPR);

  • right to withdraw consent at any time with effect for the future (Article 7(3) GDPR).

To exercise your rights, please contact me at:

birsaktranslations@gmail.com

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If you believe that the processing of your personal data infringes applicable data protection legislation, you also have the right to lodge a complaint with the competent supervisory authority.

The competent supervisory authority in Austria is:

Austrian Data Protection Authority [Österreichische Datenschutzbehörde – DSB]
Barichgasse 40–42
1030 Wien
Austria

Email: dsb@dsb.gv.at
Website: www.dsb.gv.at

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