Privacy Policy

We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This privacy policy is divided into the following sections:

Who we are

This app is operated by Subbie Tax Limited (UK company number 11520755).

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our app

This privacy policy relates to your use of our app, ‘Subbie Tax’ only.

Our collection and use of your personal information

We collect personal information about you when you access our app, register on the app, contact us via the app, purchase services through the app, complete information requests on the app.

We collect this personal information from you either directly, such as when you register on our app, or indirectly, such as your browsing activity while on our app (see ‘Cookies’ below).

The personal information we collect about you depends on the particular activities carried out through our app. This information includes:

We use this personal information to:

This app is not intended for use by children and we do not knowingly collect or use personal information relating to children (other than information on how many children some customers have in order to accurately calculate their tax affairs). For the avoidance of doubt, no personal information on individual children is collected.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

Further information—the personal information we collect, when and how we use it

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

When information is collected

What information we ask for

How and why we use your information

When you register with our app

Contact details: your name, address and email address

National Insurance number

UTR number (not compulsory to give this until we provide services to you)

We ask for this:

— to create and manage your account with us

— to communicate with you about your account

We rely on consent, contract and legal obligation as the lawful basis for collecting and using your personal information.

We will keep this information until:

— you close your account with us

— we close your account

Before we provide services to you

Identification documents such as passport or driving licence

Proof of address

We ask for this:

— to verify your identity

We rely on consent, contract and legal obligation as the lawful basis for collecting and using your personal information.

We will keep this information until:

— you close your account with us

— we close your account

When you use our app to receive services

Financial information: UTR number, bank accounts and payment details (including bank statements)

We ask for this:

— to manage your account with us

— to provide the services

We rely on contract and legal obligation as the lawful basis for collecting and using your personal information.

We will keep this information until:

— you close your account with us

— we close your account

— in the case of some financial information (including bank statements), for 6 years after you close your account with us or we close your account (for the purposes of dealing with any subsequent HMRC queries)

Viewing certain pages within the app (eg terms and conditions and privacy policy)

Session cookies (non-identifiable and randomly generated) – these will not contain personally identifiable information (other than which user is on the page if they are logged into the app)

We ask for this:

— to manage traffic on pages and keep track of visitors to the pages

— to see if users are logged into the app when they visit the pages

We rely on consent and legitimate interest as the lawful basis for collecting and using your personal information.

We will keep this information for:

— two hours in the case of non-logged in visitors

— a defined temporary period in the case of logged in visitors

Who we share your personal information with

We routinely share the above categories of personal data with FHS Accounting Limited and HMRC.

This data sharing enables (in the case of FHS Accounting Limited) us to share various back-office functions with them, and (in the case of HMRC) us to provide the services to you (being calculating tax for you).

Cookie information will be hosted on a server provided by ‘Exploding Phone’ which takes server space from its internet service provider.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party without your express consent.

Whether information has to be provided by you, and if so why

We require you to provide your name, address, National Insurance Number and email address in order to register you on our app. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

We require you to provide identification documents in order to verify your identity. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

We require you to provide your UTR number, bank accounts and payment details in order to provide the services. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our app. We use cookies on our app. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our cookie policy.

Marketing

We would like to send you information about services or offers which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email. We will only do this with your express consent on a case-by-case basis.

We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you use our app.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us at info@subbietax.com

—updating your marketing preferences on our app

It may take up to five business days for this to take place.

For more information on your rights in relation to marketing, see ‘Your rights’ below.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at ico.org.uk.

Changes to this privacy policy

This privacy policy was published on 24th March 2021 and last updated on 24th March 2021

We may change this privacy policy from time to time, when we do we will inform you via the app.

How to contact us

Please contact our Data Protection Officer, if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact our Data Protection Officer, please send an email to Info@subbietax.com or write to Subbie Tax Limited at Suite F09 Genesis Centre, Innovation Way, Stoke-on-Trent, ST6 4BF.