Privacy Policy

Introduction

We protect your personal data in line with the requirements of the General Data Protection Regulation (GDPR). The GDPR requires data controllers such as ourselves to document our lawful basis for processing personal data. It also gives you rights over how your data is processed. This privacy policy documents the data we collect, why and how we process it, and how to exercise your rights.

Data controller

The data controller responsible for this website is Pockex Tax Limited, who can be contacted at PO Box 205, Leeds, LS12 9BE. This website contains links to third-party websites, which have their own data controllers and privacy policies. This privacy policy applies only to this website.

Lawful basis for processing

For each method by which we collect personal data, this privacy policy documents our lawful basis for processing the data. Where we rely on your consent to process your data, we explain how you can withdraw your consent and delete your data.

Individual rights

The GDPR gives you rights over how your personal data is processed. You can exercise your rights by contacting us. In some cases you can also exercise your rights through automated systems, as described at the relevant points in this privacy policy.

Security

The GDPR requires us to implement appropriate technical measures to protect data. We verify the identity of any individual who requests access to data before granting access. We use Transport Layer Security (TLS, also known as SSL) to encrypt any data you supply to us through our website. Additional technical measures are described at the relevant points in this privacy policy.

Disclosures

In addition to any sharing of data described elsewhere in this privacy policy, we may disclose data for legal reasons. If we suspect criminal activity we may disclose data relating to those involved or affected to the appropriate authorities. We may also be obliged to disclose data if we receive a request from an appropriate authority.

Changes to this privacy policy

We may occasionally make changes to this privacy policy. Following any changes, the date at the top of this privacy policy will be updated. If any change allows for wider access to data, such changes will only apply to data collected after the date of the updated privacy policy.

Cookies

Cookies are small pieces of text that are stored by your browser. Each cookie has a name and is associated with a particular site. When your browser sends a request to a site (for example, to download a page, image, or video), the computer that responds (known as a server) may tell your browser to set one or more cookies. When your browser makes further requests to the same site it sends the cookies back to the server. This allows the server to remember you as you browse the site, and provide features such as shopping baskets or password-protected areas. 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.

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, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data: This includes email address and telephone numbers.
• Financial Data: This includes bank account information and payment details.
• 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.

Sharing your personal data

Pockex Tax Limited 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;
• Where we have “Legitimate Interest” to do so, including.
• 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 Pockex Tax Limited establish or become part of a group.
• Where one of our registered trading styles and/or currently 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. Currently these include:
  • Churchill Sloan
  • Quebec Legal Services
  • Quebec Partnership Limited
  • Gladstone Brookes Limited
  • FOSB
  • Easytaxrebates4u
  • Claim My Tax
• 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.
• 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:

Categories Who we use Privacy Notice

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 your lenders, underwriters, official receiver/insolvency practitioner and our processors, referrers, external auditors & 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. For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

Pockex Tax Limited processes your Personal Data for the following purposes

International Personal Data Transfer – Countries & Organisations

Pockex Tax Limited 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, Pockex Tax Limited 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 General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

Pockex Tax Limited has the following data retention policies:

• Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
• Where you have purchased, or enquired about purchasing, a Pockex Tax Limited product or services, we shall retain any personal details applicable to the contract delivery for a period of 7 years (name, email, telephone, postal address) after completion of the contract. During this time, we may contact you using consent and/or legitimate interest to market additional products or services.
• Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number, company, job title) for a period of 2 years, or until you exercise your Right to Object or opt out. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you.
• Where you have signed up to receive information emails from Pockex Tax Limited, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 2 years, or until you withdraw your consent.
• Prospect contact details. Where you have enquired about one of our products or services that is designed to assist you to claim money that you are owed, enable you to save money; and/or will strengthen your financial position we shall retain your contact details for 2 years after the date of collection, or our last positive contact, or until you withdraw your consent, whichever is latest, so that we may keep you informed if:
• We expanded our portfolio of product or service offerings;
• When we no longer need this information, we will anonymise your data and/or dispose of it securely.

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.

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:

1. 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.
2. In most cases Pockex Tax 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.
3. 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.
4. Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
5. Your right to the restriction of 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.
6. 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.
7. Your right to data portability. This only applies to the 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. Should you have a complaint please in the first instance contact our Data Protection Officer by emailing [email protected] or writing to:
   Data Protection Officer
   Pockex Tax Limited
   PO Box 205
   Leeds
   LS12 9BE.