Privacy policy

Welcome to MMP Tax’s privacy policy. MMP Tax respects your privacy and is committed to protecting your personal data.


Introduction

This privacy policy tells you how MMP Tax uses your personal data when you visit our website (regardless of where you visit it from).


It will also tell you about your privacy rights and how the law protects you.


Purpose of this Privacy policy

This privacy policy aims to give you information on how MMP Tax collects and processes your personal data through your use of this website, including any data you may provide through this website or directly to us.


It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you (e.g. when we agree to provide you with services) so that you are fully aware of how and why we are using your data.


Controller

MMP Tax Limited is the data controller in relation to our website and is responsible for your personal data (collectively referred to as MMP Tax, “we”, “us” or “our” in this privacy policy).


We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy officer here.


How to contact MMP about privacy

Our full details are:

Full name of legal entity: MMP Tax Limited (company number: 08062731)

Person responsible for data protection: the data privacy officer

Email address: you can contact the data privacy officer here.

Postal address: MMP Tax Limited. 83 Victoria Street, London SW1H 0HW

Telephone number: 0207 458 4108


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


Changes to the Privacy policy and your duty to inform us of changes

This version was last updated on 23 May 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by sending any changes to us here


Third-party links

Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


Personal data which we collect about you from our website

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title and gender.
  • Contact Data includes contact address, email address and telephone numbers.
  • Technical Data 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 includes information about how you use our website, products and services including the full Uniform Resource Locators (URL), clickstream to, through and from our sites (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as 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 policy.


We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


If you fail to provide personal data

Where we need to collect personal data whether by law, under the terms of a contract we have with you or to consider your application for a role with us, if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us or we may not be able to progress your application for a role with us. We will notify you if this is the case at the time.


How we collect your personal data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in an online form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • ask us to supply you with services;
    • apply for a role with us;
    • request marketing to be sent to you;
    • complete a survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive Identity and Contact Data about you from public sources such as Companies House.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you.
  • To consider your application for a role with us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data.


Purposes for which we will use your personal data

The table below shows you a description of all the ways we plan to use personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Type of Data
To register you as a potential or new client
  1. Identity
  2. Contact
  1. Marketing and communications
To evaluate your application for a role with us
  1. Identity
  2. Contact
To manage our relationship with you which will include
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to complete a review or survey
  1. Identity
  2. Contact
To manage and protect our business and our website (including trouble shooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  4. Usage
To deliver pertinent website content and advertisements to you and measure or understand the effectivemenss of the advertising
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Marketing and communications
To use data analytics to enhance our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
To make suggestions and recommendations about services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

We do not carry out any automated decision making.

If you ever have any questions about this, all you have to do is ask. See how to contact MMP Tax about privacy.


Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.


We may carry out direct marketing by email, phone, text or post. For example you might receive a newsletter in your inbox and you will receive marketing communications from us if you have been referred to us by a third party (with your prior consent), you have requested information from us or purchased services from us or if you have provided us with your details including when participating in a survey and, you have not opted out of receiving that marketing.


Third-party marketing

We do not share your personal data with third parties for marketing purposes.


Opting out

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it is you deciding to sign up to a newsletter or taking part in a survey – and you have a right at any time to change your mind and say no thank you and opt out. (but we would be really sorry to see you go, so please give us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of every communication.


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or application for a role with us or other transactions.


Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following types of cookies:

  • Analytical/performance. They allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functional. These cookies are used to recognise you when you return to our website so for example, you are not asked to consent to us using cookies each time you visit us.
  • Targeting and remarketing. These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website more relevant to your interests. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Further, Google has developed a browser add-on to allow users to opt-out of Google Analytics across all websites. However, please note that 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.


If you want more information about Tracking Data, in particular cookies, detailed information about the Cookies currently in use is below.



Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in the section: How we use your personal data .

  • Service providers acting as processors based in the EU or US who provide IT and system administration services to us.
  • Professional advisers acting as data processors including accountants, lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance, tax and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


International transfers

Many of our external third-party service providers (for example our cloud storage provider) are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


Data security

We have put in place 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Details of retention periods for different aspects of your personal data which you can request by contacting us.


In some circumstances you can ask us to delete your data: see below request erasure for further information.


In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • If you wish to exercise any of the rights set out above, please contact us.


No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Changes to our Privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy


Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.