Privacy Policy
Policy version: Version 1 – 13th August 2026
1. INTRODUCTION
This Privacy Policy is provided by Tax Bridge Solutions, a company registered in England and Wales under company number 17309194 with registered office at 39 High Street, Orpington, England, BR6 0JE (‘we’, ‘our’ or ‘us’) for use of our products and services, including tax rebate and agent services. (Services).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2. WHAT THIS POLICY APPLIES TO
This Privacy Policy applies to personal data processed by TBS in connection with:
- enquiries about the Services;
- Client registration, account creation and onboarding;
- identity, eligibility, anti-fraud and verification checks;
- preparation, review and submission of tax rebate claims, tax returns and related documents;
- communications with HMRC and other relevant third parties;
- HMRC agent authority, repayment nomination and refund handling arrangements;
- payment of TBS fees and remittance of refund balances;
- Client support, complaints, disputes and service administration;
- marketing preferences and service communications; and
- TBS’s legal, tax, accounting, compliance, insurance and record-keeping obligations.
The Services may link to, integrate with or rely on apps, websites, APIs, software or services operated by third parties. Those third parties may process personal data under their own privacy notices where they act as independent controllers.
For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3. PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
|
Category of data |
In more detail |
|
Identity and account data |
Name, date of birth, National Insurance number, Unique Taxpayer Reference, address, previous addresses, contact details and copies or details of identity documents. |
|
Account and onboarding data |
Account registration details, login records, Client reference numbers, service selections, acceptance records, authority records and Client instructions. |
|
Employment and income data |
Employer details, employment history, PAYE records, tax codes, payslips, P45s, P60s, P11Ds, CIS statements, Self Assessment records, income records, pension information and benefits information. |
|
Tax claim and tax return data |
Tax years, tax history, expenses, mileage, tools, uniform, professional subscriptions, construction industry scheme information, repayment calculations, claim forms, tax returns, supporting documents and correspondence. |
|
HMRC data |
HMRC correspondence, notices, statements, calculations, authorisations, repayment information and information obtained through properly authorised HMRC agent processes. |
|
Financial and payment data |
Refund amounts, fee calculations, VAT amounts, invoices, payment records, bank account details and refund remittance details. |
|
Verification, security and fraudprevention data |
Proof of address, identity verification results, fraud screening information, account security logs and risk indicators. |
|
Communications data |
Emails, letters, call notes, call recordings where used, app messages, support tickets, complaints and feedback. |
|
Technical and usage data |
Device information, IP address, browser type, operating system, app usage, access times, security logs and cookie or analytics data where applicable. |
|
Marketing preference data |
Marketing opt-ins, opt-outs, communication preferences and consent records. |
|
Data collected when you use specific functions in the Services |
Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were) |
|
Other data the Services collects automatically when you use it |
Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use. |
|
Data collected when you make an enquiry with us |
Name and email address. |
If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
TBS may process special category personal data where it is relevant to a Service requested by the Client, included in documents supplied to TBS, required for a claim or return, or relevant to a complaint, dispute, fraudprevention issue or legal obligation.
Special category personal data may include, for example, health or disability information, trade union membership information, or other information revealing matters treated as special category data under data protection law.
TBS will only process special category personal data where an Article 6 lawful basis applies and a separate Article 9 condition or Data Protection Act 2018 condition applies. Depending on the circumstances, this may include explicit consent, establishment or defence of legal claims, substantial public interest conditions, or another lawful condition.
TBS does not generally require criminal offence data for the Services. If criminal offence data is processed, TBS will only do so where permitted by law and subject to appropriate safeguards.
5. HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you:
- directly from the Client, including through forms, uploads, app screens, calls, emails, letters and other communications;
- from HMRC, where TBS has appropriate authority to act for or correspond about the Client;
- from employers, payroll documents, accountants, bookkeepers, tax advisers or other persons authorised by the Client;
- from identity verification, fraud-prevention, payment, banking, app, hosting, CRM, document management and IT service providers;
- from public registers, official records or publicly available sources where relevant to the Services;
and
- from professional advisers, regulators, law enforcement bodies, courts, tribunals or public authorities where relevant.
TBS must not request, collect or use Client HMRC online sign-in details, GOV.UK One Login details, Government Gateway credentials, digital certificates or personal HMRC passwords. HMRC access must be handled through proper agent authorisation processes.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this changes, you would be notified of this change, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant Cookies Policy.
6. HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
|
Category of data |
In more detail |
|
Responding to enquiries and assessing whether TBS can provide Services |
Pre-contract steps; legitimate interests in responding to enquiries and managing business intake |
|
Create and manage your account with us |
To perform our contract with you, to take steps at your request before entering into a contract or legitimate interests in account administration and security |
|
Verifying identity, eligibility and authority |
Contract; legal obligation; legitimate interests in fraud prevention and service integrity |
|
Providing services and/or the functionalities of the Services to you |
Depending on the circumstances:to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) |
|
Maintaining records of claims, returns, authority, communications and payments |
Legal obligation; legitimate interests in audit, complaint handling and legal claims |
|
To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances: • to comply with our legal and regulatory obligations • in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
|
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
|
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices |
Depending on the circumstances: • to comply with our legal and regulatory obligations • in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you |
|
Protect the security of systems and data |
To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
|
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
|
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app |
|
Updating and enhancing user records |
Depending on the circumstances: • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) • to comply with our legal and regulatory obligations • where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services |
|
To comply with our legal and regulatory obligations |
Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services |
|
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: • to comply with our legal and regulatory obligations • in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets |
Where TBS relies on legitimate interests, those interests may include providing and improving the Services, maintaining accurate records, preventing fraud, securing systems, administering payments, dealing with HMRC, handling complaints and disputes, obtaining professional advice, and operating TBS’s business efficiently.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
7. WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- HMRC;
- accountants, tax specialists, subcontractors and consultants assisting TBS with the Services;
- app, hosting, CRM, document management, communications, email, IT support, analytics and security providers;
- identity verification, fraud-prevention, payment processing, banking and refund handling providers;
- professional advisers, including lawyers, accountants, auditors, insurers and insurance brokers;
- debt recovery providers, where TBS fees remain unpaid;
- regulators, law enforcement agencies, courts, tribunals, public authorities and government bodies where required or permitted by law; and
- prospective buyers, investors, funders or restructuring parties in connection with a business sale, merger, acquisition, investment, financing, restructuring or insolvency process. external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including
a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
8. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
9. DE-IDENTIFIED INFORMATION
The personal data we collect may have analytical, educational, or commercial value to us. Where we have deidentified the information we have collected, we reserve the right to process and distribute such information.
10. AUTOMATED DECISION-MAKING
We may use automated systems to make decisions that significantly affect you. These processes may involve the use of personal data to evaluate you. You may request human review of any automated decision by contacting us using the details below.
11. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
As part of providing the Services, we may share your personal data with third parties based outside of the UK.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
12. YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
|
Access to a copy of your personal data |
The right to be provided with a copy of your personal data. |
|
Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data. |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations. |
|
Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
|
To object to use |
The right to object: • at any time to your personal data being used for direct marketing (including profiling) • in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests. |
|
Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us using the contact details below. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
13. KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www. getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303
123 1113.
15. CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
16. HOW TO CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:
Name: Kyle Richards
Email: admin@taxbridgesolutions.co.uk
