In this Policy we describe how we collect and process your personal information when using the professional services offered by S Tax and/or by using this website, including by setting out the conditions under which we may process any information that we collect from you or that you provide to us.
Stanley Tax Associates Ltd (trading as S Tax) is the controller of your personal data and is responsible for your personal data (collectively referred to as “S Tax”, “we”, “our”, or “us”.
Our company registration number is: 07691766, and our registered head office is located in 16-17 Queens Road, Brighton, BN1 3WA.
There are many ways you can contact us, including by phone, email and post:
Method of Contact
E-Mail Address: firstname.lastname@example.org
Phone Number: 0207 147 9940
16-17 Queens Road
You have the right to make a complaint at any time about how we process your personal data, to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues
(www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
1 Identity Data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2 Contact Data, which includes billing address, delivery address, email address and telephone numbers.
3 Financial Data, which includes bank account and payment card details.
4 Asset Portfolio Data, including details of properties bought or sold and associated tax calculations if applicable.
5 Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us.
6 Technical Data, which 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 this website.
7 Profile Data, which includes the nature, type and frequency of your use of our services, your interests, preferences, feedback and survey responses.
8 Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9 Your correspondence and communications with us including feedback and survey responses.
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.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through the following means:
• You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you and/or the business that you work for do any of the following:
o enquire about our products or services, and/or engage with us in any related interactions and communications; o provide to us your instructions for STax services;
o engage in ongoing communications in respect of services provided / that we provide to you, including any follow-up services and/or post-service communications; o subscribe to our service or publications; o request marketing to be sent to you; or o give us feedback or contact us for any other reason.
We may also obtain the personal data shown above from third parties that have your authorisation to pass information to us, such as a solicitor or accountant.
We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers such as Google based outside the EU.
• Identity and Contact data obtained via the chat feature on our website.
• Identity and Contact Data from publicly available sources including Companies House, HM Land Registry, local authority planning portals, estate gazettes and/or equivalent services, AML online searches, third party publications, property platforms and the Electoral Register.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you to provide professional services.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract, or until you cease visiting our website and subject to our data retention policy.
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information.
You may withdraw your consent at any time by contacting us using the contact details above.
We are committed to keeping your personal data safe and secure. Our security measures include the following:
• encryption of data;
• implementing risk management and data impact assessment analysis;
• regular cyber security assessments of all service providers who may handle your personal data;
• security controls which protect our IT infrastructure from external attack and unauthorised access, including the use of antivirus and antispyware specialist software, two-factor authentication, password protections and Windows security policies;
• internal policies setting out our data security approach and training for staff;
• a granular approach to information-access; and
• regarding our service providers and suppliers, in order to make certain services available to you, we may need to share your personal data with some of our service partners, these can include, cloud storage and IT providers. We only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to us and to you, and for no other purposes.
Aside from our service providers and other legal entities within our group, we will not disclose your personal data to any third party unless we are legally obliged to do so. We will never sell or rent our client data to other organisations for marketing purposes.
We may share your data with Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers to:
• comply with our legal obligations;
• exercise our legal rights (for example in court cases);
• assist in the prevention, detection, investigation of crime or prosecution of offenders; and
• assist in the protection of our employees and clients.
To deliver a full range of services to you, it may be necessary for us to share your data outside of the European Economic Area. This will typically occur when service providers, e.g. cloud services, are located outside the EEA (Third Country) or if you are based outside the EEA. These transfers are subject to special rules under data protection legislation and regulations, for example, the EU – US Privacy Shield. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice will be to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed from the link below:
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities; • to support a claim or defence in court.
We have a legal obligation to ensure we do not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of data.
Due to the work we do and the connection it has to taxation advice, which may be scrutinised by Her Majesty’s Revenue and Customs (“HMRC”), we retain all client files and records for a minimum of 6 years plus current year, otherwise known as the 6 years +1 rule.
For other types of data, meaning data not connected to advice that we provide about tax, we will retain those records for 2 years.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.