1. Introduction
This privacy notice provides you with details of how we collect and process your personal data in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 including any information you may provide through our website when you purchase a service, sign up to our newsletter or take part in a prize draw or competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
Neptune Tax Limited are the data controller, and we are responsible for your personal data (referred to as “we” in this privacy notice).
We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice, please get in touch with Joe Waterman, the Data Protection Officer using the details set out below.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Office of the Data Protection Authority on 01481 742074 or email info@odpa.gg. We would be grateful if you would contact us first if you have a complaint so we can try to resolve it.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at joe@neptune.co.gg.
2. What Data We Collect About You
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, last name (including maiden name), username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of your purchases.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data, but this data does not reveal your identity and, as such, in itself is not personal data. An example is when we review your Usage Data to determine the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data 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. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you). If you don’t provide us with the requested data, we may have to cancel a service you have ordered, but if we do, we will notify you at the time.
3. How We Collect Your Personal Data
We collect data about you through a variety of different methods, including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our services;
- create an account on our site;
- subscribe to our service or publications;
- request resources or marketing be sent to you;
4. How We Use Your Personal Data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between 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 ground for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at joe@neptune.co.gg.
Purposes for processing your personal data
Below is a description of how we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at joe@neptune.co.gg if you need details about the legal ground we rely on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us |
To manage our relationship with you, which will include the following: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our services |
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation |
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy |
To use data analytics to improve our website, services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests to define the types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy. |
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests to develop our services and grow our business |
Marketing communications
You will receive marketing communications from us if you have:
- requested information from us on purchased services from us, or
- if you provided us with your details when you entered a competition or registered for a promotion or free resources and
- in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at joe@neptune.co.gg at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us due to a service purchase, warranty registration, service experience or other transactions.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at joe@neptune.co.gg.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and explain the legal grounds of processing.
We may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. 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 paragraph 4 above:
- Service providers who provide IT and system administration services.
- Professional advisers, including lawyers, bankers, auditors and insurers, providing consultancy, banking, legal, insurance and accounting services.
- Tax authorities, regulators and other authorities based in Guernsey, the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Many of our third-party service providers 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 do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
6. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed without authorisation, 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 such data. They will only process your personal data on our instructions and 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.
7. 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.
By law, we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
In some circumstances, you can ask us to delete your data. See below 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. We may use this information indefinitely without further notice to you.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at https://www.odpa.gg/information-hub/information-rights/.
If you wish to exercise any of the rights set out above, please email us at joe@neptune.co.gg.
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.
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 security measure ensures that personal data is not disclosed to anyone with 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.
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 several requests. In this case, we will notify you and keep you updated.
9. Third-Party Links
Our website 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 your data. 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 notice of every website you visit.
10. Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or malfunction.