Privacy Policy
1 Introduction
This Privacy Policy (the “Policy”) describes the information we collect from you and how that information is used and shared by us. It applies to personal data that you (or someone on your behalf) provide to us. We may process personal data provided to us for any of the purposes described in this Policy or for other reasons if we tell you them in advance. If you are our client, this Policy should be read in conjunction with the contract you enter into with us (“Engagement Agreement”).
We are committed to respecting the privacy and confidentiality of personal data and complying with data protection legislation. When we process personal data in:
- the United Kingdom we do so in compliance with the Data Protection Act 2018 and the UK GDPR;
- the European Economic Area we do so in compliance with the EU GDPR; and
- Australia we do so in compliance with the Privacy Act 1988.
2 About us
“Expat Tax Online”, “we,” “us” and “our” refers to each company in the Expat Tax Online Group as set out here:
Expat Tax Online LLC – 5900 Balcones Drive, Suite 5037, Austin, TX 78731, United States of America
Expat US Tax Limited – Blake House, 18 Blake Street, York, YO1 8QG, United Kingdom
Expat US Tax LLC – 5900 Balcones Drive, Suite 5037, Austin, TX 78731, United States of America
Expat Solutions India Pvt Ltd – Office 1208, Godrej Genesis, Plot XI, Sector V, Salt Lake, Kolkata 700091, West Bengal, India
Expat Solutions Philippines Inc. – One West Aeropark Building, 8th Floor, Clark Global City, Clark Freeport Zone, Philippines
Expat US Tax – Box 1219, 116 74 Stockholm, Sweden
Each company in the Expat Tax Online group of companies is a separate legal entity and a separate controller of personal data. We may change the details in this section (2) from time to time.
3 How to contact us
If you wish to discuss any data protection matter please contact the Data Protection Officer:
The Data Protection Officer – Expat US Tax Limited, Blake House, 18 Blake Street, York, YO1 8QG, United Kingdom. Tel +44 (0)1904 211 005. Email info@expatustax.com
4 Our role
Our role as a controller or a processor depends upon the nature of our engagement with you. If you are a client this will be defined in our contract with you. But generally:
- Where we decide the purpose and means of processing, we are a controller;
- Where we jointly decide the purpose and means of processing with you, we are a joint controller; and
- Where we process personal data according to your explicit written instructions, in a contract that satisfies Article 28 of the GDPR, we are a processor.
5 How we obtain personal data
Personal data is any information that could identify a living person. We only collect personal data that is necessary and we ask clients to only share personal data that is required. If you provide us with unnecessary personal data, we either return it to you or destroy it if you prefer.
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6 The personal data that we process about you:
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7 Special category personal data
Unless we have a legal basis for doing so we do not collect special category personal data such as health, race or ethnic origin. For certain services or activities, and when required by law or with an individual’s consent this may be necessary.
8 Purpose for the processing and the legal basis for the processing
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9 Retention of personal data
We retain personal data in accordance with legal, regulatory and contractual requirements.
10 Data sharing
We only share personal data with other organizations when we have a lawful basis to do so and when we do so, we put contractual arrangements and security mechanisms in place to protect personal data and to comply with our data protection, confidentiality and security standards.
10.1 Data sharing within the Expat Tax Online group of companies
Personal data held by us may be transferred to, or disclosed to, other companies in our group of companies. We may do this where necessary for administrative purposes and to provide professional services to our clients. All companies in our group are bound by a Data Sharing Agreement which commits them to share personal data in a secure and lawful manner that respects the rights and freedoms of data subjects.
10.2 Data sharing with other controllers
Depending upon the nature of the service being provided to you we may lawfully share personal data with other organizations. This may change from time to time.
We use specialist organizations to provide certain services, such as data hosting. These organizations (data processors) are bound by a written contract which defines their tasks and responsibilities. We only employ processors that comply with data protection legislation and processors are subject to audit or certification review to ensure continuing compliance. The processors we use may change from time to time.
11 International transfers
We are part of a global association of tax consultants and we sometimes use organizations located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located.
We will not transfer or process personal data outside the country in which a client has contracted, or allow third parties to do so, unless it done in an approved manner in accordance with appropriate levels of security and data protection.
12 Profiling and automated decision-making
We do not perform any profiling based on personal data that has a legal or significant effect upon data subjects. We do not perform any automated decision-making involving personal data.
13 Your rights
You have the following rights concerning your personal data:
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14 Your right to lodge a complaint with a supervisory authority
If you would like to exercise any of your rights shown above, please contact the Data Protection Officer by post, telephone or by using the email address detailed in section 3.
If you are not satisfied with the response you receive, you have the right to lodge a complaint with the relevant supervisory authority for the territory in which you are contracted as shown in the table below:
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© 2021 Expat Tax Online – This Policy is version 20210726 – Published 26 July 2021
