Last updated: December 16, 2025
Version: 1.0
This Privacy Policy describes how Gi.Vi. Holdings Ltd processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and UK GDPR.
1. Data Controller
Gi.Vi. Holdings Ltd
Company Number: 15830977
Registered Address: 12-16 Lionel Road, Canvey Island, England, SS8 9DE
Privacy Contact: privacy[@]giviholdings.com
This Privacy Policy describes how Gi.Vi. Holdings Ltd processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and UK GDPR.
2. Personal Data We Collect
When you request a quote or translation service, we collect:
Types of documents processed:
Important: These documents contain special categories of personal data (Article 9 GDPR) and may contain judicial data.
Through cookies and similar technologies:
For complete details, see our separate Cookie Policy.
3. Legal Basis and Purposes
Purpose | Legal Basis | Retention Period |
|---|---|---|
Provide translation quote | Contract performance (Art. 6.1.b) | 30 days from request |
Execute NAATI certified translation | Contract performance (Art. 6.1.b) + Explicit consent for special data (Art. 9.2.a) | 1-12 months from delivery |
Administrative and accounting management | Legal obligation (Art. 6.1.c) | 10 years |
Respond to information requests | Legitimate interest (Art. 6.1.f) | 30 days |
Customer support | Legitimate interest + Contract performance | 36 months from last activity |
Statistical analysis (GA4, Zoho PageSense) | Legitimate interest (Art. 6.1.f) | 26 months |
CRM profiling for recurring customer discounts | Consent (Art. 6.1.a) | 36 months of inactivity |
Direct marketing (when activated) | Consent (Art. 6.1.a) | Until withdrawal |
Advertising remarketing (when activated) | Consent (Art. 6.1.a) | See Cookie Policy |
4. Data Recipients
Provider | Service | Data Location |
|---|---|---|
Zoho Corporation | CRM, Desk, Forms, SalesIQ, PageSense, Books | EU/USA (DPF certified) |
Google LLC (Alphabet Inc.) | Google Workspace, Drive, Analytics 4, Fonts, Tag Manager | EU/USA (DPF certified) |
Stripe Inc. | Payment processing | EU/USA (DPF certified) |
Brizy Cloud (AWS) | Website hosting | EU (AWS data centers) |
Cloudflare Inc. | CDN, DNS, security | Global network |
Wisernotify | Testimonial widget, WhatsApp button | As per provider policy |
Your documents are shared with freelance NAATI certified translators located in Australia to perform the translation service.
Legal basis for transfer:
Safeguards:
Where legally required, data may be disclosed to:
5. International Transfers
Recipients: Google LLC, Zoho Corporation, Stripe Inc., Cloudflare Inc.
Legal basis:
These providers are DPF certified and provide adequate level of data protection.
Verify certifications:
Recipients: NAATI certified translators (freelance)
Legal basis:
These providers are DPF certified and provide adequate level of data protection.
Safeguards:
Australia does not have an EU adequacy decision but has robust privacy laws (Australian Privacy Act 1988 + Australian Privacy Principles).
6. Retention Periods
Data Type | Retention Period |
|---|---|
Quote requests not accepted | 30 days from request |
Client documents (Google Drive) | 1-12 months depending on time of year (annual deletion in January) |
Email communications (Zoho Desk) | 36 months from last activity |
Translator emails | 30 days after Cost of Goods Sold registration in Zoho Books |
CRM records | 36 months of inactivity |
Administrative/accounting data (Zoho Books, Stripe) | 10 years (legal obligation) |
Analytics cookies (GA4) | 26 months |
Analytics cookies (Zoho PageSense) | 14 months |
Exception for legal disputes: In case of claims, complaints, or litigation, we retain data necessary to defend our rights until resolution + 6 years (ordinary prescription period), pursuant to Art. 6.1.f GDPR (legitimate interest - defense of rights).
7. Security Measures
Technical measures:
Organizational measures:
8. Your Rights
Right | Description |
|---|---|
Access (Art. 15) | Obtain a copy of your data and information about processing |
Rectification (Art. 16) | Correct inaccurate or incomplete data |
Erasure (Art. 17) | Obtain deletion of data ("right to be forgotten") when no longer necessary |
Restriction (Art. 18) | Restrict processing in certain cases (e.g., disputing accuracy) |
Portability (Art. 20) | Receive data in structured format and transfer to another controller |
Objection (Art. 21) | Object to processing based on legitimate interest or for marketing |
Withdraw Consent (Art. 7.3) | Withdraw consent at any time without affecting lawfulness of prior processing |
Complaint (Art. 77) | Lodge a complaint with the competent supervisory authority |
Send a request via email to: privacy[@]giviholdings.com
Include:
Response time: Maximum 1 month from request
Cost: Free (unless requests are manifestly unfounded)
United Kingdom (legal headquarters):
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone: +44 0303 123 1113
Website: https://ico.org.uk
Italy (if Italian user):
Garante per la Protezione dei Dati Personali
Piazza Venezia 11, 00187 Roma
Phone: +39 06 696771
Website: https://www.gpdp.it
9. Cookies
This website uses cookies and similar technologies. For complete information, see our separate Cookie Policy.
Cookie types:
You can modify cookie preferences through the cookie banner on the website or browser settings.
10. Profiling and Automated Decisions
Profiling:
We use limited profiling to:
Legal basis: Consent (for discounts) / Legitimate interest (aggregate statistics)
We do NOT use profiling for automated decisions that produce legal effects or similarly significantly affect you.
Automated decisions:
We do NOT use fully automated decision-making systems. All decisions (quote acceptance, pricing, service delivery) involve human evaluation.
11. Minors
The service is exclusively intended for individuals 18 years of age or older.
We do NOT knowingly collect data from individuals under 18 years of age.
Note: We may receive documents relating to minors (e.g., birth certificates, school documents) if provided by parents/legal guardians of legal age who request the service.
12. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy.
In case of substantial changes:
We recommend consulting this page periodically.
13. Contact
For any questions about this Privacy Policy or the processing of your data:
Email: privacy[@]giviholdings.com
Subject: "Privacy - [YOUR NAME]"
We will respond within 1 month of receiving the request.
N.A.A.T.I. Translations
Naati Translations | Service operated by ISS Education
International Study Solutions division of Gi.Vi. Holdings Ltd
iss-edu.com | giviholdings.com
© 2025 Gi.Vi. Holdings Ltd | Registered Office: 12-16 Lionel Road, Canvey Island, England, SS8 9DE | UK Company Reg. No: 15830977