Taxway is committed to protecting the privacy and security of your personal information, as part of our General Data Regulation (GDPR) obligations. This privacy notice for Taxway LTD describes how and why we might collect, store, use, and/or share (‘process’) your information when you use (‘user’) our services. This relates to all activities concerning your relationship with Taxway Ltd and is not limited to the use of our website.

The Data Protection Legislation contains principles affecting not only personally identifiable information held on computers but also certain manual records containing personal data, for example associates, directors, employees, clients, or suppliers’ personnel files that form part of a structured filing system.

The data protection principles There are seven data protection principles that are central to the Data Protection Legislation. In brief, the principles say that personal data must be:

Processed fairly and lawfully and must not be processed unless certain conditions are met in relation to personal data and additional conditions are met in relation to sensitive personal data. Obtained only for one or more specified and lawful purposes and must not be processed in any manner incompatible with those purposes. Adequate, relevant, and not excessive in relation to the purposes for which it is processed. Taxway will review files on a regular basis to ensure they do not contain a backlog of out-of-date or irrelevant information and to check there is a sound business reason requiring information to continue to be held. Accurate and, where necessary, kept up to date. Not kept for longer than is necessary Appropriate technical and organisational measures must be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, data. Have appropriate measures and records in place to be able to demonstrate compliance with the legislation.

The Data Controller Taxway Ltd is the Data Controller for any personal data that you give us.

Taxway Ltd decides how and why personal data is processed – ensures that appropriate technical and operational measures are in place so that, by default, only personal data which are necessary for each specific purpose of the processing are processed. This applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. Through these measures, the controller ensures that, by default, personal data are not made widely accessible without permission.

Our full details are: Taxway Ltd, 35 Burgrange Park, Dalkeith, Scotland, EH22 4FR

Email: hello@taxwayuk.com

The Data Protection Officer {DPO} is responsible for ensuring that appropriate Privacy Notices exist and are appropriately published to enable all data subjects to be aware of these notices and their contents before data is collected. All content will be in plain language.

Our nominated representative for the purpose of the regulations is Isaac Stannard.

The information we collect and when

We only collect information that we know we will genuinely use and in accordance with the Data Protection Legislation. This includes, but not limited to:

information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views);

information relating to any transactions carried out between you and us on or in relation to this website, including information relating to the supply of our services;

information that you provide to us for the purpose of registering with us (including name, address, telephone number and any financial information);

information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters);

information required to complete our services that we will request directly from you, including your personal circumstances and information about your financial products and services; and

any other information that you choose to send to us

All personal data we hold is processed by our staff in the UK

How we use your information To contact you, following your enquiry.

To reply to any questions, suggestions, issues or complaints you have contacted us about.

Make available our services to you.

Take payment from you or give you a refund.

For statistical analysis and to get feedback from you. For example, occasionally we may invite you to review a service you’ve used from us.

To power our security measures and services so you can safely access our website.

Help us understand more about you as a customer, the services you use, so we can serve you better.

To carry out an electronic Anti Money Laundering (AML) identity check.

Contact you about services from us.

Contact you about services from our affiliates.

To improve customer service and support your needs more efficiently.

Lawful basis We are required by law to always have a permitted reason or justification (called a “lawful basis”) for processing your personal data. There are six such permitted lawful bases for processing personal data.

The lawful basis for processing your data is based on your specific consent, performance of a contract, compliance with a legal obligation or our legitimate interest that we will have stated at the point the information was initially provided.

Please note that where our processing of your personal data is either:

necessary for us to comply with a legal obligation; or

necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it,

and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract with you.

In respect of our legitimate interests, we have a legitimate interest in keeping you updated about any further services offered by us which may be of interest to you both during and after the conclusion of your contract with us, including communication of any developments that may have an impact on your original service (e.g. a change in the law that will make additional services available to you). We will use the details you have provided to contact you including by telephone, email and post. If you do not wish for us to contact you in this manner, or by a specific method, you will be able to unsubscribe at any time to one or all contact methods and this option will be easy for you to complete.

We also have a legitimate interest in using your data to help us to review our services and obtain analytics in respect of our customer base.

We may also be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling. In these circumstances, we may be required to keep your data by law. We will always inform you if this is the case.

Special category personal data (including criminal data) We are required by law to treat certain categories of personal data with even more care than usual. This includes information about your health, any disabilities you may have and your criminal convictions (spent or unspent). These are called sensitive or special categories of personal data and an additional condition set out in the Data Protection Legislation is required to process them.

The additional condition(s) we rely upon for processing special category personal data are either that the processing is undertaken by us and is not shared outside Taxway Ltd or your explicit consent.

Who we might share your information with To allow us to provide our services to you, the following third parties provide critical functions to our business and will process your personal information as directed by us and in accordance with strict data security arrangements:

Our Advertising: We use third party digital advertising services who provide analytical information about our advertising to help us improve this in the future. In any event, the data that is collected by these third parties is anonymous and does not contain any personal information.

Our Suppliers: We may need to share your data with our key suppliers. This includes but is not limited to information such as your name, address, contact details and information to verify your identity. All our key suppliers will have undergone security checks to the satisfaction of Taxway Ltd and have robust procedures in place to safeguard your information.

Law Enforcement Agencies: We may need to share your information with law enforcement agencies. For example, this could be to prevent fraud or detect crime.

The Financial Ombudsman Service: Should you wish to refer any complaint to the Financial Ombudsman Service, they will need to process your data for the purposes of dealing with your complaint. They may ask us to provide information to them to assist them in their investigations.

Fraud Prevention Agencies: Before we provide services to you, we undertake checks for the purposes of preventing fraud and money laundering. To do this, we may share your personal information with third parties, including law enforcement agencies, and these third parties may further share that information. We undertake these checks to protect our business and to comply with laws that apply to us. These checks are carried out based on the public interest of fraud prevention and to meet our legal obligations. You can find more information about how the fraud prevention agencies process personal data by visiting their respective websites at www.callcredit.co.uk/crain and www.experian.co.uk/crain.

HM Revenue & Customs: We may be required by law to share your data with HM Revenue & Customs for tax purposes.

Our Legal and Professional Advisors: We may need to share your information with our legal and professional advisors for the purposes of obtaining advice. All our legal and professional advisors are under a duty of confidentiality to us and have robust procedures in place to safeguard your information.

Our Regulator: We may need to share your information with our regulator. This could be to meet our own regulatory obligations and also so that our regulator can check that we are complying with our legal obligations and regulatory requirements.

Our Services and Joint Ventures: We may enter into joint ventures with third parties and in doing so may share your information. These third parties may include insurers, lenders, estate agents, developers, financial services providers and other professional service providers. These third parties may operate from locations inside and outside the EEA. In each case, we will ensure that we have a legitimate reason for sharing your personal information and that this is in line with this Privacy Notice.

Cookies We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. Some of the cookies we use are essential for the site to operate.

If you register with us or if you continue to use our site, you agree to our use of cookies.

You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

When you visit our site, a Cookie Control pop-up banner will appear asking for your consent to place cookies on your device.

For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

Your rights Under the Data Protection Legislation, you have the right to:

Request access to, deletion of or correction of, your personal data held by us at no cost to you.

Request that your personal data be transferred to another person (data portability).

Be informed of what data processing is taking place.

Restrict processing.

To object to processing of your personal data.

Complain to a supervisory authority.

Ask for a copy of any information about you that we hold (a subject access request).

Object to decisions being made that significantly affect you.

Object to how we are using your personal information for direct marketing purposes.

Object to our using your personal data for automated decision making.

To understand more about these rights, please see our Data Subject Rights Policy.

To exercise any of these rights, please contact our Data Protection Officer by emailing hello@taxwayuk.com or writing to the Data Protection Officer, Taxway Ltd, 35 Burngrange park, Dalkeith, Scotland, EH22 4FR. Retention of your data Taxway Ltd retains your data for no longer than is necessary. What this means will vary by the type of service we have provided you with and our regulatory obligations. Once this period has concluded, your data will be permanently deleted.

Security of your data Our offices are physically secure with access controls and all our staff have access to cloud-based applications and communications from remote locations. Any hard copy files are stored securely with physical access controls. Information is stored in the UK and all data is backed up regularly. In addition to physical security, our staff is trained to be aware of the importance of information security and maintaining the confidentiality of our clients’ and staff data.

In addition to the above measures, we have in place appropriate technical and organizational measures to ensure the security of your personal information. This includes password protection, encryption, and regular testing of our IT systems.

Data breach notification We have a data breach policy in place which would be followed in the event of a data breach. We are legally required to report any unlawful data breaches to the Information Commissioner’s Office (ICO) within 72 hours of the breach occurring. If the breach is deemed to be of high risk to individuals, we are also legally obliged to inform those individuals without undue delay.

We will report any data breach to our regulator without undue delay and in any event within 72 hours of having become aware of it.

In the event that your data is compromised, Taxway Ltd will notify you and our regulator as quickly as possible, and will communicate with you about the steps you need to take to protect yourself.

Changes to our privacy notice We will update our privacy notice from time to time and any changes will be posted on our website. This privacy notice was last updated on 2nd December 2023.

Contact us If you have any questions or comments regarding this privacy notice, please contact us by emailing hello@taxwayuk.com or writing to the Data Protection Office.

If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way that is inconsistent with the law, you can complain to the Information Commissioner’s Office (ICO) whose helpline number is 0303 123 1113.

---

Please note that you should carefully review and customize this document to ensure it aligns with your specific business practices and legal requirements. Additionally, it’s recommended to seek legal advice to confirm compliance with relevant regulations.