We, Rebate Gateway Limited, are committed to safeguarding the privacy of our website visitors, our prospective customers (“prospects”) and our customers; this policy sets out how we will treat your personal information. If you have any questions about this policy or our treatment of your personal data, please contact us:
- by email at: email@example.com
- by post to: Data Protection Officer, 7 Bell Yard, City of London, WC2A 2JR
- by telephone on: 0333 444 1054
Our data protection registration number is ZA766745. Our company is registered in England and Wales.
Throughout this document we refer to the provision of our ‘Tax Rebate Services’. A definition of Tax Rebate Services can be found within our Terms of Engagement.
HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you register a claim with us.
- you engage us to provide our services and also during the provision of those services.
- you contact us by email, telephone, post or social media (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer or HMRC).
THE TYPE OF INFORMATION THAT WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name, address, contact details, national insurance number and employment related information)
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services.
- details of any services you have received from us.
- information about any complaints and enquiries you make to us.
- information from research, surveys, and marketing activities.
- Information we receive from other sources, such as publicly available information, information provided by your employer or information from HMRC.
HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you (for example to process your tax refund claim or tax return) and to comply with our legal obligations.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL DATA
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes.
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided.
- any statutory or legal obligations.
- the purposes for which we originally collected the personal data.
- the lawful grounds on which we based our processing.
- the types of personal data we have collected.
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
We have a Legitimate Interest in keeping both prospects and customers updated about any further services offered by us which may be of interest to you, including communication of any developments that may have an impact on the original service you engaged with us about (e.g. a change in the law that will make additional services available to you) and/or similar products and services. In these instances we may also provide a referral to a solicitor within our legal panel with your consent, including our legal partner(s).
‘Legitimate Interest’ means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].
For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
When establishing a ‘legitimate interest’ for communications/promotions to prospects, we adhere carry out a 3-stage Legitimate Interests Assessment (LIA) where we look to:
- Identify a Legitimate Interest
- Carry out a Necessity Test
- Carry out a Balancing Test
Should you no longer wish to receive information about similar products and services, you can always withdraw your consent to receive marketing communications from us and we will stop processing your data for marketing purposes. You are able to withdraw your consent verbally via telephone or in writing via email or post using the contact details found on the specific marketing communication and at the beginning of this policy.
CHANGE OF PURPOSE
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services, postal services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data.
We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
In order to meet our contractual and legal obligations, we several companies / services / data processors to help us perform various activities such as general administration, case review, compliance with anti-money laundering obligations, these are:
Perren Consultants Limited
Conclusive Financial Limited
Phillipson Hardwick Advisory Limited
KBM UK Limited
What about other third-parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
We will share your personal data with HMRC in order carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services).
TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We may transfer and store the personal data we collect about you to countries outside of the EEA in order to perform our contract with you.
There is an adequacy decision by the European Commission in relation to these countries therefore it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your right in certain circumstances, by law you have right to:
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please write to email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Rebate Gateway Limited 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.
Should you also wish to opt out of Google Analytics tracking across all websites please visit http://tools.google.com/dlpage/gaoptout
CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be located at rebategateway.org/privacy-policy.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer at firstname.lastname@example.org