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BACKGROUND:

Venn Accounts Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us
Venn Accounts Ltd.
Private limited company registered in England under company number 09268775.
Registered address: 86-90 Paul Street, London, England, EC2A 4NE.
VAT number: GB202014487.
Data Protection Officer: James Ripley.
Email address: james@vennaccounts.com.
Telephone number: 020 8088 2590.
Postal address: 86-90 Paul Street, London, England, EC2A 4NE.
We are regulated by ICO. Registration number: ZA545804.
We are a member of ICB and CIMA

2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the UK Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.

4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data to merely storing;
f) The right to object to us using your personal data for a particular purpose or purposes. This means that where we are processing your personal data by relying on our, or a third party’s, legitimate interest, you have the right to object to such processing. However, we may demonstrate that we have compelling legitimate grounds for processing which override your interests and rights.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling – We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.

Data Collected How We Collect the Data
Identity Information including name, title, date of birth, gender, national insurance number, and unique tax reference numbers.
Post, email or telephone.
Contact information including email address, telephone number.
Post, email or telephone.
Business information including business name, job title, profession.
Post, email or telephone.
Payment information including card details, bank account numbers.
Post, email or telephone.
Data from third parties including Tax code notices, student loan notifications.
HMRC portal, post, email or telephone.
Sensitive data, such as data concerning health, collected to meet our legal obligation to process payroll. HMRC portal
Your preferences in receiving marketing information from us. Post, email or telephone.

6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Supplying our services to you. Any data supplied and those noted in section 5.
Consent and contract.
Communicating with you. Any data supplied and those noted in section 5.
Consent and contract.
Complying with our regulatory and legal obligations Any data supplied and those noted in section 5.
Legal obligation
Provide you with marketing-related information. Any data supplied and those noted in section 5.
Consent and legitimate interest.

We will also use your personal data where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
a. Where we need to protect your interests (or someone else’s interests).
b. Where it is needed in the public interest.

We will only provide you with marketing-related information after you have, where legally required to do so, opted-in to receive those communications. If you have not opted-in to receive market related information, we will use your personal data for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms. You have the right to object to such communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Following this, we will delete your personal data. However:
a) if we are required by any regulation or law to retain it for longer, we will retain it for the required period; and/or
b) where the personal data is being used in connection with legal proceedings (including prospective legal proceedings) it will be retained for the duration of those legal (and any enforcement) proceedings.
Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Data Collected How Long We Keep It
Identity Information including name, title, date of birth, gender, national insurance number, and unique tax reference numbers.
As long as required to perform service.
Contact information including email address, telephone number.
As long as required to perform service.
Business information including business name, job title, profession.
As long as required to perform service.
Payment information including card details, bank account numbers.
As long as required to perform service.
Data from third parties including Tax code notices, student loan notifications.
As long as required to perform service.
Sensitive data, such as data concerning health, collected to meet our legal obligation to process payroll. As long as required to perform service.
Your preferences in receiving marketing information from us. As long as you accept marketing communications from us. We will securely delete such data in accordance with applicable law upon request.

8. How and Where Do You Store or Transfer My Personal Data?

We transfer personal data to jurisdictions as necessary for the purposes described above, including to jurisdictions outside of the UK or EEA, which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. With respect to such cross-border data transfers, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Data Protection Legislation.
We have put in place appropriate physical, technical and administrative security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we take a number of important measures, including the following:
• Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are required to do so;
• File encryption;
• Staff training about the importance of confidentiality and maintaining the privacy and security of your personal data;
• Securely locked filing cabinets for documentation;
• Real-time protection anti-virus, anti-malware and anti-spyware software;
• Unique passwords;
• Regular software updates;
• Timely decommissioning and secure wiping of old software and hardware;
• Data backup;

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

9. Do You Share My Personal Data?
We may share personal data with third parties in the following instances:
a) We share personal pata with suppliers and service providers to enable such parties to perform functions on our behalf and under our instructions. This includes, for example, payroll services.
b) If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
c) In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of James Ripley:
Email address: james@vennaccounts.com.
Telephone number: 020 8088 2590.
Postal Address: 86-90 Paul Street, London, England, EC2A 4NE.
At our discretion, we may request you to prove your identity before providing you with the requested services and/or information.

12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available at vennaccounts.com/privacy. You agree it is your responsibility to monitor these changes on our site. This Privacy Notice was last updated on 6 June 2022.

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