We Luv Tax Limited. Privacy Notice

This Privacy Notice is 4.0 and is valid from 00:01 hrs on 20.06.2023. It replaces and supersedes all other Privacy Notices associated with We Luv Tax Ltd.

We take your privacy very seriously. This Privacy Policy details what personal data we collect and how we shall use it.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Our Name & Contact Details.

The Data Controller of your personal data is WeLuvTax Limited. This means that WeLuvTax decides how your personal data is processed and for what purposes. Our contact details are:

We Luv Tax Limited
PO Box 205

Leeds

LS12 9BE

Data Protection Officer Contact Details.

In observance of the UK General Data Protection Regulation and the Data Protection Act 2018, WeLuvTax have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing DPO@weluvtax.co.uk  or writing to:

Data Protection Officer

We Luv Tax
PO Box 205

Leeds
LS12 9BE

 

Personal data categories we collect

We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

  • Identity Data: This includes first name, last name, marital status, title, date of birth, National Insurance Number
  • Contact Data: This includes postal address, email address and telephone numbers.
  • Financial Data: This includes bank account information and payment details. PPI refund amount & tax amount, salary, pension, state benefit details, other taxable income.
  • Compliance Data: This includes recorded calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.
  • Technical Data: This includes internet protocol (IP) address, 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.
  • Usage Data: This includes information about how you use our website, products and services.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.
  • Aggregated Data: This includes statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
  • Special Categories of Personal Data: This includes health and vulnerability related data that you may voluntarily share with us during the fulfilment of our services to you. We will always ask for your explicit consent to record and share Special Category Data.

 

Cookies

For more information on the cookies we use, see our cookie policy.

Data collected by third parties on our behalf

Google Analytics

We use Google Analytics to track visitor interaction with our site in order to produce statistical reports. Google collects details of the pages you view and the time you viewed them, the features of your browser, and your IP address. We have enabled IP anonymisation so that Google will not store your complete IP address. For more information on how Google handles the data it collects, see Google’s privacy policy. To opt out of Google Analytics tracking on our site, see the Google Analytics section of our cookie policy. To opt out of Google Analytics tracking on all sites, use the Google Analytics Opt-out Browser Add-on. Lawful basis for processing: Pursuance of our legitimate interests Why? To allow us to analyse how visitors interact with our site in order to improve our site and our services

Other data collected by third parties

Facebook page widget
When you view a page containing the Facebook page widget, your browser connects to Facebook. For more information on how Facebook handles the data it collects, see Facebook’s privacy policy.
Twitter profile widget
When you view a page containing the Twitter profile widget, your browser connects to Twitter. For more information on how Twitter handles the data it collects, see Twitter’s privacy policy.

 

For what purposes do we process personal data, and what are the lawful Basis’ by which we process data?

WeLuvTax processes your Personal Data for the following purposes:

For What Purposes Do We Process Personal Data?
“WeLuvTax processes your data to…”
What is the lawful basis by which we process the data?
Supply, perform, manage and fulfil our products and services to youContract
Make and manage customer paymentsContract
Manage fees and charges due on customer paymentsContract
Communicate with clients to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications;Contract
Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail and push notifications;Consent
Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications;Legal Obligation
Communicate with clients on matters where we have a legitimate interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications;Legitimate Interest
Direct market similar or aligned new products and services to our existing customers;Consent & Legitimate Interest
Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;Consent &Legitimate Interest
Verify the identity of individuals where necessary including for Subject Access Requests (SAR);Contract & legal Obligation
Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail;Legal Obligation
Gather feedback for service and product improvement via email, telephone, SMS text, postal mail;Legitimate Interest
Share testimonials, case studies and feedback on our website and future marketing;Consent
Resolve complaints and/or disputes;Legitimate Interest
Request continuation of Consent prior to consent expiry;Consent
Collect payments or arrears should we have the need to do so;Legitimate Interest
Protect our organisation, staff, associates, suppliers, partners and clients;Legitimate Interest
Prevent, detect and investigate fraud;Legal Obligation
Prevent, detect and investigate crime;Legal Obligation
Comply with the law;Legal obligation
Fulfil our statutory or regulatory obligations;Legal obligation
Maintain our own accounts and records;Legal obligation
For reporting, analytics and product/service improvement (including training);Legitimate Interest
Improve and maintain data accuracy or completeness;Legitimate Interest
Track your email engagement;Legitimate Interest
Personalise your online experience;Legitimate Interest
Conduct market research.Legitimate Interest
Sell your personal dataLegitimate Interest

 

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may:

  • Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services, a soft opt-in exists, and it conforms with the Privacy and E-Communication Regulation;
  • Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;
  • For reporting, analytics and product/service improvement (including training);
  • Improve and maintain data accuracy or completeness;
  • Track your email engagement;
  • Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
  • Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
  • Sell your personal data;
  • Resolve complaints and/or disputes;

Sharing your personal data

  • WeLuvTax may choose to share your personal data internally and/or externally to the business. Where we choose to share your information, we shall do so for the following reasons:
  • Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below;
  • Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
  • Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
  • We are required to share relevant information with other agents acting for the same client that they may need to see, for example, if we are acting on your behalf in relation to a specific relief and you have a different agent completing a tax return for you, that Agent may request that we share details of our work so that they can compile your tax return. We would only ever release information where it is relevant to the work that the other agent is doing and after satisfying ourselves that they have authority to act on your behalf in the matter.
  • Where we have “Legitimate Interest” to do so, including;
    • PockEx
    • The Genius Group (TGG)
    • Lead Insight Ltd
    • Gladstone Brookes Ltd
    • For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
    • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should WeLuvTax establish or become part of a group.
    • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help clients maximise the potential of their data in a fair, lawful and transparent manner that we do not currently provide ourselves.
    • Where one of our registered trading styles and/or current associated businesses provides a product or service that we do not and where that services is similar/aligned with our aim to help customer maximise the potential of their data in a fair, lawful and transparent manner.
    • Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and:
      • Which we reasonably believe would be of benefit to you, and you would reasonably expect to receive
      • Is similar/aligned to our organisation and the services we provide,
      • It conforms with the Privacy and E-Communication Regulation.
    • In this case we would contact you using Legitimate Interest to request specific Consent to share your personal information.
      • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
      • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
      • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:
    CategoriesWho we usePrivacy Notice
    Payment service providersSage Pay, DPShttps://www.sagepay.co.uk/policies/privacy-policy
    Web analytics service providersGoogle Analyticshttps://policies.google.com/technologies/partnersites?hl=en-US
    Customer Relationship Management SystemCMS – Lantechttps://www.lan.co.uk/
    IT support providersLantechttps://www.lan.co.uk/
    Call & SMS Communication ProviderConnex Diallerhttps://www.connexone.co.uk/privacy-policy/
    Mail scanning & support providersRNBhttps://www.rnbgroup.co.uk/privacy-policy/
    Feedback/review service providersSurvey Monkey Inchttps://www.surveymonkey.com/mp/legal/privacy-policy/

    Where we choose and/or have your permission to share your personal data with 3rd Parties we will, where appropriate, ensure that they have signed a contract that requires them to:

    • Abide by the requirements of all relevant data protection and privacy legislation;
    • Treat your information as carefully as we would;
    • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
    • Allow us to carry out checks to ensure they are doing all these things.

    If you provide your data through a third party, we may share data with that lead provider in order to assist with the management of the services and to streamline client contact.

    We may, from time to time, disclose your data to and receive from the HMRC, official receiver/insolvency practitioner and our processors, referrers, external auditors, compliance advisors & regulator.

    We may have to disclose your personal data with other third parties as set out below. These organisations or bodies will not use your information to contact you. These third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.

    • HM Revenue & Customs: We’re required to disclose certain data with the HMRC.
    • There may be other regulators and authorities such as Solicitors and Accountants, acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

    Right to Withdraw Consent

    • If we are processing your data based on you having given us consent to do so, you have the right to withdraw this consent at any time and we will stop processing your data for that particular activity. To withdraw your consent, please email us at DPO@weluvtax.co.uk

      

    Selling your personal data

    WeLuvTax may choose to sell your personal data.

    You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

    Where we choose to sell your information, we shall do so in the following circumstances:

    • Where we have your “Consent” to do so;
    • Where we have a “Legitimate Interest” to do so, including;
      • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
      • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

     

    International Personal Data Transfer – Countries & Organisations.

    WeLuvTax may transfer personal data to countries outside of the UK and/or EEA. Specifically, we use data processors based in South Africa.

    If data is transferred outside of the EEA, WeLuvTax will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the UK General Data Protection Regulation and Data Protection Act 2018.

    Personal Data Retention Period

    WeLuvTax maintains a retention schedule which defines for how long we will store your personal data. We will only store personal data for as long as we have a legitimate need to retain it, either for statutory/legal reasons or because we need the data to be able to provide you with services or for other legitimate business needs.

    When we no longer need this information, we will anonymise your data and/or dispose of it securely.

    A copy of our retention schedule is available by request to the DPO.

    The rights available to individuals in respect of the processing

    Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

    • Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. . In most cases WeLuvTax will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 28 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
    • Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. 
    • Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. 
    • Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. 
    • Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. 
    • Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. 

    If you wish to exercise any of your individual rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing DPO@weluvtax.co.uk 

    Automated decision-making, including profiling.

    When using some of our services you may have the option to undertake our Digital Journey, which is an automated online experience. We have built logic and analysis into our Digital Journey that will make decisions on the validity of your case submission, but you can rest assured that throughout this process there is the facility to query the processing with us in person.

    For more information on how our Digital Journey works and the automated decision making, please feel free to get in touch with our Data Protection Officer.

    To restrict marketing for services that you have already expressed an interest in we may use your data to check which services you have expressed an interest in and hash the data in house in order to ensure that your personal data is not disclosed during this process.

     

     

    Your Right to Lodge a Complaint with the ICO

    You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, WeLuvTax would like the opportunity to address any complaint you may have.

    Should you have a complaint please in the first instance contact our Data Protection Officer by emailing DPO@weluvtax.co.uk or writing to:

    Data Protection Officer

    We Luv Tax Limited

    PO Box 205,

    Leeds,

    LS12 9BE

    If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire.
    SK9 5AF.
    Or by telephone on 0303 123 1113.