Effective 16 January 2019
At The Tax Refund Company, we’re committed to protecting your privacy.
We want to make it easy for you to find out how we use your information.
We’ve tried our best to explain things in a simple and clear way and welcome your questions and comments on this policy.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how The Tax Refund Company uses your data.
The following data privacy notice explains the circumstances in which The Tax Refund Company will collect personal data from you, why it is being collected, how we will use it and to whom we might disclose it to if necessary.
The Tax Refund Company is a trading name of PTS (Stockport) Limited.
The Data Controller
The Tax Refund Company is committed to complying with the UK’s Data Protection law and the EU General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services.
If you have any questions about this privacy notice or how we use your personal data, please contact:
Data Protection Officer
The Tax Refund Company
Phone: 0161 968 7300
Email: gdpr@thetaxrefundcompany.co.uk
What data is being collected and processed?
In order to enter into an agreement with The Tax Refund Company we will collect, store and use elements of your personal data. The processing of this personal data is a contractual requirement and is necessary by The Tax Refund Company in order to administer your account and to provide the services you have requested from us.
To provide you with our services, The Tax Refund Company will usually need you to disclose the following:
- title
- first name
- last name
- date of birth
- email address
- full address, including postcode
- landline telephone number and mobile number
- Marital status
- Spouse / Civil Partner’s details (if relevant)
- employment details
- any other details specific to the circumstances you tell us about which will help us identify any potential claim on your behalf
Any personal data we collect from you will be stored and transferred in line with the requirements of the General Data Protection Regulation (GDPR).
Website cookies
Cookies are small files which are stored on your device when browsing websites. When you visit our website temporary data about your visit is stored. This information helps us to better understand how our site is used, including the number of visitors we have, the pages viewed per session and the time spent on pages. This in turn helps us to provide you with a better experience, since we can evaluate the level of interest in the content of our website and tailor it accordingly.
The following data is collected and stored by The Tax Refund Company until deletion:
- IP address of the accessing computer/device
- date, time and duration of your visit
- name and URL of the accessed pages
- identification data of the browser and operating system used
- website from which the data was accessed
- name of your internet service provider
The nature and content of the information collected via cookies differs, as does the period for which this information is retained. In line with our data protection obligations, we will ensure that this retention period is not excessive, and that the data is only retained for as long as is necessary for the purpose for which it was collected.
Why we use cookies:
The Tax Refund Company uses different types of cookies to help improve your online experience, these include:
- Website usability and functionality: cookies allow you to move around the different pages of the websites without retyping in any previously typed information. They also help us to guarantee your security or predict how our website will perform during your visit.
- Website analytics: allow us to note which pages of the websites you visit and how you browse. This allows us to know how many people visit our website and see which pages are visited, as well as log any page errors you experience. These cookies do not collect any personal information that could identify any individual visitor to our websites.
- Website analytics: are linked to third parties such as Twitter, Facebook and Google, and when a link is clicked, they may later be used by those organisations to pass information about your browsing to other marketing agencies. As a result, these agencies may place adverts that you may be of interest to you when you visit other websites.
Most browsers automatically accept cookies but you can set your browser options so that you will not receive cookies and you can also delete any existing cookies from your browser. Visit www.allaboutcookies.org to find out how you can restrict or prevent cookies, depending on the web browser you are using. Please note, you may find that some parts of our website will not function properly if you refuse cookies.
Should you also wish to opt out of Google Analytics tracking across all websites please visit http://tools.google.com/dlpage/gaoptout
Marketing and other communications
The Tax Refund Company does not actively market products to clients. However, if you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.
You have a right to opt-out of our communications at any time (provided they are not specific to the functioning of any service with us). You can opt-out simply by emailing online@thetaxrefundcompany.co.uk
Links to websites of other providers third parties
Please note that this data privacy notice only applies to The Tax Refund Company and we are not responsible for, and have no control over, information that is submitted to or collected by third parties, such as those where our website may provide links to third-party sites. Since we do not control those websites, you are responsible for reviewing and abiding by the privacy policies of these third party sites to ensure they comply with the applicable data protection regulations.
How long will the data be stored for?
Where possible, The Tax Refund Company will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for its processing and retention.
As a general rule, if you enter into or took steps to enter into a contract The Tax Refund Company we will store the data for a period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims.
Under the GDPR, you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’. Specific circumstances in which you can request the deletion or removal of personal data includes:
- where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
- where you withdraw consent
- when you object to the processing and there is no overriding legitimate interest for continuing the processing
- where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- where the personal data has to be erased in order to comply with a legal obligation
- in case a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.
Sharing of data with other data controllers
At The Tax Refund Company, we take your privacy seriously and the information we hold about you is confidential. We will only disclose it outside The Tax Refund Company when:
- you have given us your consent to do so
- it is necessary for the performance of an agreement of which you will be made aware
- in order to obtain professional advice (e.g. legal advice)
- we or others need to investigate or prevent crime (e.g. to fraud prevention agencies)
- the law permits or requires it
- regulatory or governmental body requests or requires it, even without your consent, or
- there is a duty to the public to reveal the information
In order to administer our service, we may need to share some of your personal information with other data controllers. This is necessary for the purposes of delivering specific services to you.
Who we share your information with and why:
We sometimes share the information that you or our systems give us with third party companies and individuals. This helps us to provide you with a better service.
The third parties that we share your information with includes:
- HMRC when we are submitting a claim on your behalf
- Third party companies or individuals that we employ to process information on our behalf based on our instructions and in compliance with this Privacy Policy. These include but are not limited to:
- Google Analytics is a web analytics service offered by Google which tracks and reports website traffic
- Social media and review sites (Facebook, Twitter, Linked In, YouTube, Trust Pilot) allow you to give us feedback so that we can improve our service. If you follow us or share posts we can share information with you that you might find useful
- Campaign Monitor allows us to send, receive and track the emails we send to you
- Mimecast allows us to send the emails we send to you
- Survey Monkey is a survey tool we use to ask you questions and learn about how we could improve our service to you
- Visual Website Optimiser is a website research and testing platform that allows us to improve our online experience for you by learning how you use our website
- WordPress is the system we use to place content for our website and you are able to posts comments on some of the information
- We may also share data with security consultants to help us get better at identifying spam. Some information we get may be collected by third-party providers on our behalf
We will also monitor, and store any telephone, email or other electronic communications with you for training purposes so that we can improve the quality of our customer service.
Fraud Prevention
If you give us false or inaccurate information and fraud (in any form) is identified, details will be passed to the fraud prevention agencies and/or Law enforcement agencies. We and other organisations may also share, access and use this information to prevent fraud and money laundering. We only share information if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public; or to detect, prevent, or otherwise address fraud, security or technical issues.
Protecting your privacy
In order to protect the personal data collected from you by The Tax Refund Company against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors and other support staff are obligated to observe confidentiality and data privacy.
Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the Internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.
All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation. You must not use any false identity in email or other network communications and you must not attempt or participate in the unauthorised entry or viewing of another user’s account or into another system.
You must not use the services and/or network systems or any part thereof for fraudulent activities, or to breach another organisation’s security (cross-network hacking). This is an illegal act and prosecution under criminal law may result. You must not use any computers, computer equipment, network resources or any services provided by us for any illegal purpose, or for accessing, receiving or transmitting any material deemed illegal, indecent, offensive or otherwise unacceptable under UK law.
We will monitor network traffic from time to time for the purposes of backup and problem solving and in order to ensure that you are not misusing any of the services provided to you.
Breaches
If at any time we become aware that your data has been compromised, or that a breach of our systems and controls has occurred, which has an impact on the security of your data, we will notify the Information Commissioner’s Office, and you, without undue delay.
Subject Access Requests
You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you for a ‘reasonable fee’ of £25 inc. VAT we can refuse to respond when a request is manifestly unfounded, excessive or repetitive.
If you would like a copy of the information we hold on you, or believe that we are holding information about you which is incorrect or incomplete, please write to:
The Tax Refund Company Compliance Unit
Seaton House
St. Thomas’s Place
Stockport
SK2 6LR
Email: gdpr@thetaxrefundcompany.co.uk
We will respond to your request without delay and at the latest, within one month of receipt of your request.
Rectifying or updating personal data
If you believe the personal data we hold about you is inaccurate or incomplete, you have the right to rectification. You can let us know about any changes to. Where possible, we will also inform any third parties to whom we have disclosed the personal data in question to so they can rectify their records.
We will typically respond to your request within one month, although this can be extended by two months if your request for rectification is complex.
Right to complain
If you have a complaint about any aspect of data protection or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact:
Group Data Protection Officer
The Tax Refund Company
Seaton House
St. Thomas’s Place
Stockport
SK2 6LR
Email: gdpr@thetaxrefundcompany.co.uk
If you are unhappy with the final response you have received from The Tax Refund Company you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO) within three months of your last meaningful contact with us. You can call the ICO on 0303 123 1113 or visit https://ico.org.uk .
Changes to the Privacy Policy
Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. The Tax Refund Company reserves the right to change this data protection information at any time with effect for the future.
The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.
Last updated: 16 January 2019