Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Equifino Limited | |
Our data protection officer | Paul Netto who is contactable at email address: Paul.netto@equifino.co.uk | |
Personal data | Any information relating to an identified or identifiable individual | |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation |
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Data subject | The individual who the personal data relates to |
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Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of providing accountancy services to your business.
Personal data we will collect | Personal data we may collect depending on why you have instructed us |
Your name, address and telephone number Information to enable us to check and verify your identity, e.g. your date of birth or passport details Electronic contact details, e.g. your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction | Your National Insurance and tax details Your bank and/or building society details Details of your professional online presence, e.g. LinkedIn profile Details of your spouse/partner and dependants or other family members if they are involved in your business Your employment status and details including salary and benefits which may be required for us to give you advice on tax issues where relevant. Personal data we may collect depending on why you have instructed us To give you advice on tax where relevant Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to other financial arrangements Personal identifying information e.g. if you instruct us to incorporate a company for you. |
We collect and use this personal data to provide accountancy services. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
How your personal data is collected
We collect most of this information from you, direct. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g.:
- credit reference agencies;
- from a third party with your consent, e.g.:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- via our website—we use cookies on our website (for more information on cookies, please see our cookie policy)
- via our information technology (IT) systems, eg:
- via our case management, document management systems;
How and why we use personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
Preventing and detecting fraud against you or us | For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. rules issued by our professional regulator | To comply with our legal and regulatory obligations
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To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, i.e. to protect our business, interests and rights |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: —for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory |
What we use your personal data for | Our reasons and obligations |
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, client base, services range or other efficiency measures. | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Preventing unauthorised access and modifications to systems | Depending on the circumstances: —for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations |
Protecting the security of systems and data used to provide services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Updating and enhancing client records | Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, e.g. making sure we can keep in touch with our clients about existing and new services |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
What we use your personal data for | Our reason: best service to you |
Marketing our services to: —existing and former clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings | For our legitimate interests, i.e. to promote our business to existing and former clients |
External audits and quality checks, e.g. for ISO, or Investors in People accreditation and the audit of our accounts | Depending on the circumstances: —for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
Purpose | Processing operation | Lawful basis relied on under the UK GDPR and EU GDPR | Relevant categories of personal data |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other | Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018, UK GDPR and the EU GDPR | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number and company details —your account details username |
| Addressing and sending communications to you as required by law | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
| your name, address and contact information, including email address and telephone number and company details —your account details (username) |
Addressing and sending communications to you about changes to our terms or policies or changes to the services or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number and company details —your account details (username) |
How and why we use your personal data—Special category personal data
Certain personal data is treated as a special category to which additional protections apply under data protection law:
- We do NOT collect and process special category data
Where special category personal data is collected or used this would only be permitted under data protection laws where, e.g.:
- we had your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent.
- We do NOT collect and process special category data.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for more information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at info@equifino.co.uk ;
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our insurers and brokers;
- our bank;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
We will not share your personal data with any other third party.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out in the table below.
Recipient | Processing operation (use) by recipient | Relevant categories of personal data transferred to recipient |
Senta Saas Limited with company number 08964408 and registered office at Heathrow Approach, 4th Floor, 470 London Road, Slough, England, SL3 8QY | The operation of a customer relationship system which stores a copy of your personal data on computer equipment so it can be accessed by us and permitted third parties (see below) online>
| For Senta Saas Limited the customer relationship system company: Any of the personal data we collect about you. |
AMAZON DATA SERVICES IRELAND LIMITED with registered number 390566 and registered address ONE BURLINGTON PLAZA, BURLINGTON ROAD, DUBLIN 4, DUBLIN, D04RH96, IRELAND
| Your data is shared by Senta Saas Limited with Amazon Data Services Ireland Limited in order to obtain web hosting and backup of data services | Any persona data we collect about you. |
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, to comply with legal and regulatory requirements of HMRC.
As a general rule, if we are no longer providing services to you, we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
- our service providers Senta Saas Limited with company number 08964408 and registered office at Heathrow Approach, 4th Floor, 470 London Road, Slough, England, SL3 8QY who use Amazon AWS for web hosting and backup of your data which is based in the Republic of Ireland where your data will be transferred to Amazon Data Services Ireland Limited with registered company number 390566 and registered address one Burlington Plaza, Burlington Road, Dublin 4, Dublin D04RH96, IRELAND .
- As we are based in the UK we will also transfer your personal data from the EEA to the UK
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. Currently, we do not transfer your data to any country outside the UK/EEA.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. Currently, we do not transfer your data to any country outside the UK/EEA.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
International transfers of your personal data outside the UK—in more detail
More details about the countries outside the UK to which your personal data is transferred are set out in the table below.
Recipient country | Recipient | Processing operation (use) by recipient | Lawful safeguard |
Republic of Ireland | AMAZON DATA SERVICES IRELAND LIMITED with registered number 390566 and registered address ONE BURLINGTON PLAZA, BURLINGTON ROAD, DUBLIN 4, DUBLIN, D04RH96, IRELAND
| Web and data hosting services, that stores a copy of your personal data on computer equipment so it can be accessed by us and permitted third parties online in order to run our business and provide services
| Adequacy regulation further to paragraph 5(1)(a) of Part 3 of Schedule 21 to the Data Protection Act 2018 |
International transfers of your personal data outside the EEA—in more detail
Currently, we do not transfer your personal data outside the EEA
Transferring your of your personal data within the EEA
If you would like further information about data transferred to countries within the EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access | The right to be provided with a copy of your personal data | |
Rectification | The right to require us to correct any mistakes in your personal data | |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations | |
Restriction of processing | The right to require us to restrict processing of your personal data—in certain situations, e.g. if you contest the accuracy of the data | |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations | |
To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims. | |
Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
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The right to withdraw consent | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by <insert details of how depending on the consents given> Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
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For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or 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:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and client or matter reference number)] and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures 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.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK;
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
This privacy policy was published on 22/08/2022 and last updated on 22/08/2022.
We may change this privacy policy from time to time, when we do we will inform you via info@equifino.co.uk.
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details | Our Data Protection Officer’s contact details |
128 City Road, London, EC1V 2NX 0117 203 4010 | Insert contact address Insert contact email address Insert contact telephone number |
Individuals in the EEA
Currently, we do not offer our services to individuals in the EEA.