At Tax Natives LLP, we respect your privacy and are committed to protecting your personal data. In this policy, we explain how we collect and use your personal information when you visit our Tax Natives platform (which includes our website [https://taxnatives.com] and our Tax Natives mobile app), use our services or otherwise contact us (regardless of where you visit it from).
We are the data controller for the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR), which means that we decide how and why we use your personal data within our business. We are registered with the Information Commissioner’s Office under registration number [TO INSERT IN DUE COURSE].
If you have any questions about your privacy on our Tax Natives platform, or our use of your personal data, please contact us.
Please note that links from our Tax Natives platform may take you to external websites, plug-ins and applications, which are not operated by us or covered by this policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We recommend that when you leave the Tax Natives platform that you read their privacy policies before submitting any personal information to other sites.
What personal information do we collect, and how do we use it?
You are not required (by law or by any contract with us) to provide personal information to us via our Tax Natives platform. We will only require you to provide personal information to us where it is necessary for us to provide you with a service at your request. If you fail to provide required information, we may be unable to provide certain services.
Providing our services
We will collect personal information about you if you use our Tax Natives platform, if you enquire about, or purchase, the products and services that we offer (including if you register for a Tax Natives account), and if you subscribe to our newsletter and/or email notifications. This may include:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title and date of birth.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services purchased from advisers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Tax Natives platform.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. This may also include any additional information users choose to disclose when seeking an adviser, for example as to the nature of advice they are seeking.
- Usage Data includes information about how you use our Tax Natives platform, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We have a legitimate interest in efficiently and effectively managing and operating our business, and improving the services that we offer, to give you the best customer experience that we can. As a customer, we sometimes need to use your personal information to do this. We also need to use this information to perform our obligations when we enter into contracts with you. We will use your information so that we can:
- Provide you with information about our products and services and your contracts with us
- Register and manage your Tax Natives account
- Verify your identity
- Deal with any complaints you may have
- Administer and manage our services and relationship with you, including dealing with customer satisfaction enquiries
- Improve the services that we offer, including the performance of our systems, processes and our people
- Administer and protect our business and the Tax Natives platform (including troubleshooting problems, analysing statistics, maintenance, support, reporting and hosting of data, conducting research and tests and keeping the Tax Natives platform secure)
- Deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- If you are seeking advice:
- put you in touch with advisers, where you request us to do so
- If you are (or acting on behalf of) an adviser:
- promote your services via the Tax Natives platform
- undertake credit checks on new providers
- manage payments, fees and charges, including collecting and recovering debt
Promoting our Services
We may use the personal information that we hold about you (such as your name and email address) to identify and tell you about our products and services that we think may be of interest to you. [This includes our newsletter.]
If you are a customer or we have provided you with a quote for our products and services we may also contact you with information about similar services that we offer.
We have a legitimate interest to use your personal information in this way to promote our services and further our business, but you may contact us at any time to let us know if you do not wish to receive these messages.
If you are not a customer, we will not use your personal contact details for marketing purposes unless you have given us consent to do so, and you may withdraw your consent or update your preferences at any time by contacting us.
Information we collect on our Tax Natives platform
When you visit our Tax Natives platform, we may collect the following information:
- Identity, Contact and Financial Data that you provide to us by filling in forms on our Tax Natives platform or by corresponding with us by post, phone, email or otherwise.
- Which pages you view and which links you follow
- Your IP address and general location
- Details of the hardware and software that you are using to access the Tax Natives platform
- Any usernames and passwords that you use on our Tax Natives platform
- If you choose to log in using a third party, we will record your log-in provider
- A device identifier (cookie or IP address) for fraud prevention
- Details of your visits to our Tax Natives platform and the resources that you access, including, but not limited to: traffic data, location data, web logs and other communication data
- Where you access our Tax Natives platform from advertising sources, we record the source of each visit. This is purely to allow us to assess the effectiveness of these adverts and is not used for customer profiling of any kind
Our Tax Natives platform is not intended for children and we do not knowingly collect data relating to children.
Keeping in touch
Information we receive about you from other sources
Sometimes you will have given your consent for other websites, services or third parties to provide information to us.
This could include information we receive about you if you use any of the other websites that we operate or the other services that we provide, in which case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on the Tax Natives platform. We will also have told you for what purpose we will share and combine your data.
We may also receive information from third parties that we work with to provide our services, such as clients or advisers (as applicable) that you engage with after connecting on our Tax Natives platform, payment processors, technical support companies and advertising companies. Whenever we receive information about you from other third parties, we will let you know what information we have received and how and why we intend to use it if such use is not already addressed by this policy.
How else might we use your personal data?
In some cases, we may collect personal information about you from other sources. This may include:
- Analytics providers such as Google based outside the UK.
- Publicly available information from sources, such as Companies House and the Electoral Roll based inside the UK
- Information you have shared publicly, including on social media
- Information from third party databases, such as credit reference agencies
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money laundering and other crimes. We may also use your information where it is necessary to protect your interests, or the interests of others, or in accordance with our legal obligations. This may include in the event of criminality, such as identity theft, piracy or fraud.
We will only use your personal information for the purposes for which we collected it (as explained in this policy) unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Who do we share your personal information with?
We share the information that you provide to us with our staff so that we can manage our business and provide our services to you. We may also share your information with selected third parties, such as:
- Our web hosting provider, [Insert name of Provider – e.g. AWS] to host the website and related services and applications
- Our IT and technical support providers
- Our suppliers [Insert name of Suppliers]
- Service providers acting as controllers who provide tax-related services (please also see section Third-party links)
- Payment service providers, for making and receiving payments
- Contact management systems to send emails, instant messages, social media messages and SMS messages
These third parties only use your personal data on our instructions, in order to provide certain services, and we do not permit them to use your data for any other purpose. Sometimes we share your data with third parties who do use that information for their own purposes, for example:
- Advisers we promote via the Tax Natives platform, where you express an interest in contacting them
- Mobile application stores
- Payment service providers, for making and receiving payments
- Our trusted professional advisers, such as lawyers and accountants, where appropriate
We may also disclose your information to other third parties where we believe that the disclosure is:
- Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
- Necessary to protect the safety of our employees, our property or the public
- Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction
- Proportionate as part of a merger, business or asset sale (in the event that this happens we may share your information with the prospective seller or buyer involved)
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Advisers may also be based on other territories.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long do we keep your personal information?
We will only store your personal information for as long as we need it for the purposes it was collected for. For example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or payment information will only be held for as long as necessary to process the transaction.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where we provide you with any service, we need to retain the information we hold about you for at least as long as we continue to provide that service to you.
If you are a customer, we may retain the information we hold about you, including your contact details and order history, for a period of [6 years] from our most recent engagement with you.
If you are a user of our Tax Natives Platform or we have otherwise been in contact with you, we may retain the information we hold about you for a period of up to [3 years].
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Thereafter, and in all other circumstances, we will only keep your information for as long as is strictly necessary to allow us to achieve the original purpose for which that information was collected.
Protecting your personal information
We put in place appropriate security measures to keep your personal data secure and to prevent unauthorised access.
Information that you provide via our Tax Natives platform is hosted with [e.g. AWS] on secure third party servers in the UK. We try to ensure that all information you provide to us via the Tax Natives platform is transferred securely. When using our website, always check for the padlock symbol in your browser and “https” in the URL before submitting information. However, the transmission of information via the internet is not completely secure and, although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Tax Natives platform.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
What rights do you have?
You have a number of rights in respect of your personal data. If you would like any further information or to exercise any of your rights, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In most cases, we will not charge you any fee if you wish to exercise any of these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
The right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to comply with this right, but please contact us if you require further information.
The right to access your personal data
You have the right to ask us to confirm whether or not we hold any of your personal data. If we do, you have the right to access a copy of your data, as well as information about how, and why, we use it. In order to prevent your data being disclosed to someone who is not authorised to access it, we may have to verify your identity before we provide you with a copy of the data that we hold.
The first copy of your information that you request from us will be provided free of charge, if you require further copies, we may charge an administrative fee to cover our costs. Please contact us if you wish to request access to our data.
The right to correct any inaccurate or incomplete personal data
If the information that we hold about you is inaccurate or incomplete, you have the right to require us to correct that data (or complete it by supplementing it with other information).
The right to be forgotten
You have the right to require us to delete or destroy your personal data in the following circumstances:
- The information is no longer needed for the purposes for which we collected it
- Where we rely on your consent, and you withdraw that consent
- You object to us using your information for marketing purposes, or for our legitimate interests, and we have no overriding reason to keep using it
- We have used your information unlawfully
- We are required by law to delete your information
If these situations apply, you may contact us to request that we erase your data from our systems.
The right to have your data transferred to you or a third party in a common format
Where your personal data is processed by automated means, you may have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format, and to ask us to transfer this data to another organisation in a safe and secure way.
You have the right to object to direct marketing
You can ask us at any time to stop using your information for direct marketing purposes, even if we do not rely on your consent to do this. You may exercise this right by following the instructions in any of the emails that we send to you, or by contacting us.
The right to object to us using your information for our own legitimate interests
Sometimes, we use your personal information to achieve goals that will help our business – these are our legitimate interests, and they are explained in more detail in this policy.
We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object to our use of your data in these ways. If you do object to this, unless we have a compelling reason to continue, we will stop using your personal data for these purposes.
You have the right to restrict how we use your personal data
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
- You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify or update this
- You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
- We have used your information unlawfully, but you do not want us to delete it
- We no longer need to use the information, but you need it for a legal claim
You have rights related to withdrawing consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have rights related to automated-decision making and profiling
You have the right not to be subject to decisions made based on automated decision-making, including profiling, which will have a legal effect upon you or otherwise significantly affect you. We do not currently use any automated decision-making or undertake any profiling of our customers or other individuals.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This version was last updated on [INSERT DATE] and historic versions can be obtained by contacting us.
If you wish to make a complaint about our collection or use of your personal data, please contact us in the first instance so that we may seek to resolve your complaint.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website if you wish to lodge a complaint with the ICO. If you are based in a European Union member state, you may instead lodge a complaint with the supervisory authority in your country.
If you wish to speak to us regarding your privacy, or our use of your personal data, please contact us using the following details:
Post: Tax Natives LLP, 20-22 Wenlock Road, London, England, N1 7GU
Email: [INSERT EMAIL ADDRESS]