Taxnova Ltd

1. Introduction

This privacy policy applies to Taxnova Ltd (“we”, “us” or “our”). We are committed to protecting your privacy. This policy explains how we collect, use and share your personal data.

Where we collect personal data directly — for example from website visitors or prospective customers — we act as a data controller and this policy applies in full. Where we process personal data on behalf of our clients as part of our R&D tax credit claim preparation services, we act as a data processor on the client’s behalf. In that case, the client is the data controller and our processing is governed by a separate data processing agreement with that client. If you are an employee or contractor of one of our clients and wish to exercise your data rights, please contact your employer in the first instance.

This policy applies to all personal data we handle as a data controller, whether collected through our website, in person or through other means.

2. Information We Collect

2.1 Identity and contact details

• Name, address, email address and phone number

• Professional details

2.2 Service related information

• Enquiries about our services and communication records

• Feedback, complaints and survey responses

2.3 Financial and payment information

• Payment details for any services purchased from us

2.4 Digital information

• IP address and general location information derived from your IP address

• Search and browsing behaviour and website usage patterns

• Cookie preferences and tracking

2.5 Recordings

• Call recordings

• Records of meetings and decisions

2.6 Professional information (for job applicants and workers)

• Employment history

• Professional experience

• Required authorisations and licences

• Professional registrations

• Information about your right to work in the UK

3. How We Collect Personal Data

• Directly from you: when you interact with us, contact us, or fill out forms.

• Automatically: when you visit our website, use our technologies, or interact with our online services.

• From third parties: service providers, business partners, previous employers, government organisations and organisations or people authorised by you.

• From publicly available sources: such as Companies House and professional networking sites such as LinkedIn.

4. How We Use Your Information

Data protection law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases.

• Consent — you have clearly agreed to us using your personal data for a specific purpose.

• Performance of a contract — we need to use your information to fulfil a contract with you, or because you’ve asked us to do something before entering into a contract.

• Legal duty — we must use your information to comply with the law.

• Vital interests — we need to use your information to protect someone’s life.

• Public interest — we need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis.

• Legitimate interests — we have a genuine business reason to use your information, or a third party does, but only if this doesn’t unfairly override your rights and interests.

Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. These assessments consider the nature of our legitimate interest, the impact on you, any safeguards we can implement, your reasonable expectations, and the broader context of our relationship.

Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. We have listed the reasons we process your data and the legal basis below. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data.

5. Our Disclosures of Personal Data to Third Parties

We may disclose personal data to:

5.1 Service providers

• Infrastructure hosting and data storage: Google Cloud Platform (EU)

• LLM API processing: Anthropic (transfers outside the UK/EEA — see section 6)

• LLM API processing: Google Gemini Enterprise Agent Platform / Vertex AI (transfers outside the UK/EEA — see section 6)

• Storage and collaboration: Google LLC (Google Workspace)

• Marketing and advertising providers

• Analytics providers

5.2 Professional advisers

• Bankers

• Auditors

• Insurers and insurance brokers

• Legal advisers

5.3 Business partners

• Our existing or potential agents

• Our business partners or contractors

5.4 Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

• Your information may be disclosed to our advisers

• Your information may be disclosed to the potential purchaser’s advisers

• Your information may be included in the transferred assets

5.5 Legal and regulatory bodies

• Courts and tribunals

• Regulatory authorities including as required for reporting obligations

• Law enforcement officers

5.6 Other parties

• Third parties you have authorised

• Emergency services when necessary

• Any other parties as required or permitted by law

6. Overseas Transfers

6.1 Where we store and access your information

We store your personal data in the United Kingdom. However, your information may be transferred to locations outside the United Kingdom in these circumstances:

• When our service providers are located overseas

• When we work with overseas business partners

• When using cloud-based services or data storage solutions

• When required by law or legal proceedings

6.2 Our approach to overseas transfers

When we transfer your personal data outside the United Kingdom, we ensure it receives appropriate protection by:

• Only transferring your information to countries that UK data protection law recognises as providing adequate protection for personal data, or

• Putting in place a contract with the third party that means they must protect personal data to the same standards as the UK.

• Transferring personal data to organisations that are part of specific agreements on cross-border data transfers with the UK.

6.3 AI processing and overseas transfers

Where we use LLM API providers to process data as part of our services, some of those providers are located outside the United Kingdom. In those cases, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the UK Secretary of State (International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses) or the recipient’s participation in a valid adequacy framework recognised under UK data protection law.

6.4 What this means for you

We only transfer the minimum amount of personal data necessary and require all recipients to:

• Protect your information to the same standards required by UK law

• Use your information only for the purposes we’ve agreed

• Allow us to monitor how they handle your information

• Provide you with the same rights over your information that you have under UK law

7. Children’s Personal Data

We do not knowingly collect or process personal data from children under 13 years of age without appropriate parental or guardian consent. If you are under 13, please do not provide personal data to us without first asking your parent or guardian for permission.

If we become aware that we have collected personal data from a child under 13 without verified parental consent, we will take steps to delete that information as quickly as possible.

Parents and guardians have the right to:

• Review any personal data we hold about their child

• Request correction or deletion of their child’s personal data

• Refuse or withdraw consent for further collection or use of their child’s data

• Contact us with any concerns about their child’s privacy

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us immediately using the details provided in this policy.

8. Data Retention

8.1 How long we keep your information

We only keep your personal data for as long as we need it to:

• Provide our services to you

• Meet our legal, tax, accounting or regulatory obligations

• Handle any complaints or legal issues that may arise

We may keep your information for longer periods if:

• You make a complaint that we need to investigate or respond to

• We reasonably believe legal action involving our relationship with you might occur

• The law requires us to keep it for specific timeframes

8.2 How we decide retention periods

When determining how long to keep your information, we consider:

• How much information we have and how sensitive it is

• The risk of harm if the information was accessed without permission

• Whether we can achieve our purposes in other ways

• What legal, regulatory, tax or accounting rules require

• The nature of our relationship with you and the services we provide

8.3 What happens when we no longer need your information

Once we no longer need your personal data, we will securely delete or destroy it in accordance with our data retention policies and legal requirements.

8.4 Your rights

You can request information about retention periods for your data and ask for early deletion where legally possible.

9. Your Privacy Rights and Choices

9.1 Providing information

You can choose whether to provide personal data to us, however, if you don’t provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

9.2 Right of access

You have the right to ask us for copies of your personal data. You can request other information such as details about where we get personal data from and who we share personal data with. There are some exemptions which means you may not receive all the information you ask for.

9.3 Right to rectification

You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.

9.4 Right to erasure (“right to be forgotten”)

You can request deletion of your personal data in certain limited circumstances as set out in data protection law, such as where the data is no longer necessary or has been unlawfully processed. This right is not absolute and we may be required or entitled to retain your data for legal, regulatory or legitimate business reasons.

9.5 Right to restrict processing

You can ask us to suspend processing where:

• You contest the accuracy of the data

• Processing is unlawful but you don’t want erasure

• We no longer need the data but you need it for legal claims

• You’ve objected to processing pending verification of our legitimate grounds

9.6 Right to opt out of marketing communications

You can opt out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

9.7 Right to data portability

Where technically feasible, you can receive your personal data in a structured, commonly used format or have it transmitted to another controller where:

• Processing is based on consent or contract

• Processing is automated

9.8 Right to object

You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.

9.9 Right to withdraw consent

Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

9.10 How to exercise your rights

To exercise any of these rights, contact us using the details below. We may ask for proof of identity and will respond within one month (extendable to three months for complex requests).

These rights are available under data protection law, though some may not apply in every situation. We’ll let you know if any limitations apply when you make a request.

10. Making a Complaint

If you’re unhappy with how we’ve used your personal data, please get in touch with us first using the contact details at the end of this policy. When you contact us:

• Give us full details about your complaint and we will acknowledge your complaint within 30 days of receiving it (starting the day after we receive it). We will usually respond using the same method you used to contact us, unless you ask us to use a different method. If you contact us through social media, we will ask for an alternative secure contact method.

• We will investigate your complaint without undue delay. We will begin investigating as soon as we receive your complaint. We will review all relevant facts, speak to relevant staff, and check that we have followed our own policies and standards. The time this takes depends on the complexity and scale of the issue and any harm you are suffering.

• We may contact you for more information if we are not sure what your complaint is about or to ask what outcome you are looking for. This helps us resolve your complaint more quickly.

• We will keep you updated on progress throughout our investigation. We will provide you with updates on timeframes, explain any delays, give you an expected completion date, and provide a point of contact for any questions.

If you are not satisfied with our response to your complaint, you can also make a complaint directly to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at any time.

You don’t have to contact us first before going to the ICO, but we’d appreciate the opportunity to try to resolve your concerns directly with you.

11. Protecting Your Information

We use multiple layers of security to protect your information.

11.1 Technical safeguards

• Enterprise-grade encryption for data storage and transmission

• Regular security testing and monitoring

• Automated threat detection systems

11.2 Operational security

• Staff training on security and privacy

• Strict access controls based on job requirements

• Regular security audits and incident response procedures testing

11.3 Physical security

• Secure premises with controlled access

• Secure disposal of physical documents

• Equipment security protocols

11.4 Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

12. Cookies and Analytics

12.1 Cookies and pixels

We use cookies and similar tracking technologies on our website to enhance your browsing experience and improve our services. Cookies are small text files that are stored on your device when you visit our website. They help us remember your preferences and understand how you use our site.

Types of cookies we use:

• Essential cookies: necessary for the website to function properly

• Performance cookies: help us understand how visitors interact with our website

• Functionality cookies: remember your preferences and settings

• Marketing cookies: used to deliver relevant advertisements and track campaign effectiveness

When you first visit our website, you will see a cookie notice explaining our use of cookies. You can choose which types of cookies to accept through our cookie preference centre. You’ll find more information about the cookies we use in our cookie pop-up.

You can change your cookie preferences at any time by:

• Using our cookie preference centre on the website

• Adjusting your browser settings to refuse or delete cookies

• Visiting our cookie policy for detailed information about specific cookies

Please note that disabling certain cookies may affect the functionality of our website and your user experience.

12.2 Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google’s advertising features through your Google account settings, browser add-ons, or your device’s privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google’s privacy pages.

12.3 Meta advertising tools

We use Meta’s advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

13. Artificial Intelligence (AI) Technologies

We use artificial intelligence technologies, including third-party large language model APIs, in the delivery of our services. Details of how we use AI, the safeguards we apply, and your rights in connection with AI processing are set out in the AI-assisted processing row of the table in section 4 and in section 5 (our disclosures of personal data to third parties) of this policy.

14. Amendments

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.

15. Our Contact Details