We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.  
  
• Retention of personal date: When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:
• where tax returns have been prepared it is our policy to retain information for 7 years from the end of the tax year to which the information relates. 
• where ad hoc advisory work has been undertaken it is our policy to retain information for 7 years from the date the business relationship ceased. 
• where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 7 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.



Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.

You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:

Individuals, trustees and partnerships

• with trading or rental income: five years and 10 months after the end of the tax year;
  
• otherwise: 22 months after the end of the tax year.

Companies, LLPs and other corporate entities

• six years from the end of the accounting period.
  

Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller monthly/annually at the termination of the contract.

We may share your personal data with:

• HMRC
  
• any third parties with whom you require or permit us to correspond
  
• subcontractors
  
• an alternate appointed by us in the event of incapacity or death
  
• tax insurance providers
  
• professional indemnity insurers
  
• our professional body and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)
  

If the law allows or requires us to do so, we may share your personal data with:

• the police and law enforcement agencies
  
• courts and tribunals
  
• the Information Commissioner’s Office (“ICO”)
  

We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  
• To communicate with you and to keep you informed of our latest updates and services;
  
• To serve you advertisements when you use our Site (see more under "Advertisements"); 
  
• To market our websites and products (see more under "Marketing"); 
  
• Conducting statistical and analytical purposes, intended to improve the Site.
  

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our Site;
  
• Providing you with our services, including providing a personalised display of our Site;
  
• Storing and processing such information on our behalf; 
  
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  
• Providing you with marketing offers and promotional materials related to our Site and services; 
  
• Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

You may request to: 

1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
3. Request rectification of your personal information that is in our control.
4. Request erasure of your personal information. 
5. Object to the processing of personal information by us. 
6. Request to restrict processing of your personal information by us.
7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”), Lee Daykin (lee.daykin@onthegoaccountants.co.uk) or our Authorised Representative, Petra Faruq (petra.faruq@onthegoaccountants.co.uk)

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at info@onthegoaccountants.co.uk.

OnTheGo Accountants Limited, 5 Chancery Lane, London, EC4A 1BL.