Privacy Policy 

  1. Introduction.

1.1 Desucla Limited is a UK company (registered number  12078865) with registered office at 83 Friar Gate, Derby, Derbyshire, United Kingdom, DE1 1FL and this policy is by us and the entities we own or control (“Desucla”, “we”, “us” or “our”). Email addresses and telephone numbers can be found on the website Contact page. 

1.2 We are committed to protecting and respecting your privacy, in accordance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. Please read the following carefully to understand our views and practices regarding your Personal Data (as defined in UK GDPR) and how we will treat it pursuant to data protection laws (including the Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 as retained under UK law (UK GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended). 

1.3 Desucla is the data controller in respect of your Personal Data when you visit this website or use our Fiscal Representation or other tax payment services. If, however, we receive your Personal Data through a third party partner, with which you have contracted for such services, it shall be the data controller and we shall be the data processor; in such circumstances, please refer to their privacy policy (in addition to this policy) and in the first instance please address any queries to them. 

1.4 This Privacy Policy clarifies how we collect, store, use and protect your Personal Data using appropriate technological and organisational measures, highlights your rights and informs you whom to contact if you have further queries. 

  1. Why and on What Grounds does Desucla require Personal Data?

We process your Personal Data: 

2.1 To perform a  contract with you or with one of our partners contracted with you for tax payment services: 

  • To register you as a client or as a provider of service to us 
  • Providing and administering our services as contracted with you or to our partners contracted with you for tax payment services; 
  • Communicating with you to manage our relationship, processing payments, collecting money including fees.  

2.2 To comply with our legal requirements and adhere to regulatory and legal requirements concerned with fraud, anti-money laundering, terrorist financing and other financial criminal offences, providing data to a law enforcement agency or public body or keeping records for tax purposes and according to social security, social protection or employment law  

2.3 To conduct our business and pursue our legitimate interests. This includes: 

  • For insurance purposes 
  • Delivering reports and providing any professional advice related to our business activities, administering and managing our relationship with you, including accounting, auditing, record keeping, taking other steps linked to the performance of our business relationship; 
  • Promoting our capabilities, products and services to existing and potential clients and partners; 
  • Sending correspondence regarding access to our events and webinars; 
  • To protect our business interests, make sure complaints and concerns are comprehensively investigated, for the establishment, exercise or defence of legal claims 
  • Tailoring our client experience to match client needs, analysing and improving our services and communications and to monitor compliance with our policies and standards; 
  • To protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities,  
  • Authenticating our clients so that they may access certain areas of Desucla services. 

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. 

  1. How do we collect your Personal Data?

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

3.1 Directly: 

  • You have contacted us by telephone, post, social media, email or other electronic means; 
  • By completing one of our online forms; 
  • Subscribing to our newsletters; 
  • Registering for our webinars or events; 
  • Attending meetings or events that we host or providing us with your business card(s); 
  • Visiting our offices; 
  • On establishment of a business relationship or request for our services; 
  • Providing professional services to us; 
  • Through one of our hosted software applications. 

3.2 Indirectly: 

  • Through public registers e.g. Companies House; 
  • Through internet searches, news articles, sanction lists and other third party sources such as government agencies, credit reporting agencies, information service providers or from publicly available records.; 
  • Automated technologies: when you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns by using cookies and other similar technologies. We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy. If you were to log into our website using social media e.g. LinkedIn, Google or Twitter: this information will include your name, email address and other details depending on your privacy settings. 
  • From third party partners with whom you are contracted for tax payment services, to enable us to provide services to such partners. 
  1. What Personal Data do we collect and process?

We may collect and process the following  Personal Data: 

  • Identity and Contact data: Name, gender, age and date of birth; passport number; address, email and phone number; CCTV footage when you visit our premises; Country of residence and other data relevant to your tax payments and our contract with you or with our partner with whom you are contracted for tax payment services; 
  • Employment and education details (when you are a candidate to work with us); 
  • Technical Data: e.g. information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. 
  • Business Information: e.g. information provided as necessary for us to provide the services or otherwise voluntarily provided by you; .information regarding any complaints that you file; Your payment information, in order for us to take a payment from you for the services provided; Financial information: income, taxation, business activities, investments and other financial interests. Profile Data: How you use our products and services; posts on forums, blogs, platforms or social media applications that we provide (including ones provided by third parties); 
  • Sensitive Personal Data will be collected by us only with your consent and as necessary for the provision of tax payment services or as required by law:  e.g. in personal identification documents that may contain information regarding race, religion, ethnic origin, biometric data of private individuals and beneficial owners of corporate entities;; regarding potential or existing criminal convictions or offences; health records; 
  • Child data: Desucla do not intentionally collect data from individuals under 13 years of age, but where it is collected, special measures are in place to ensure consent and its security. 

Opt-Out: If you choose not to provide, or object to us processing the Personal Data we collect, we may not be able to continue to provide some or all of our services to you. 

You may, however, opt -out of marketing. If you are a client, we would like to use your Personal Data to communicate with you about future services or updates we think may be of interest. If you do not want us to contact you in this way, you can opt out of these communications at any time by following the opt-out links on any message or by emailing us at: [email protected]. 

  1. For How long do we retain Personal Data?

5.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including to continue to provide services, maintain a point of contact for when required and to adhere to professional obligations, regulations and applicable laws. for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims. As a standard policy we will retain your data for seven years, however, we may be required to retain your data for a greater period of time under special circumstances i.e. if there are investigations in respect to the service provided or where a greater retention period is required by law. 

5.2 Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations. 

  1. With whom do we share your Personal Data?

6.1 We may disclose your data to the following: 

  • Third parties that support us in our business operations e.g. IT support, cloud-based software services, telecommunication providers, document production services and mailroom support; 
  • Our professional advisors e.g. insurers, auditors and lawyers; 
  • Banks and payment service providers and other credible third parties that we rely on to help us deliver efficient contracted services.  
  • Fiscal Representatives (Tax agents appointed by you or us to act as a conduit for payments in the respective jurisdiction and to be nominated as tax payment beneficiaries) 
  • Tax payment beneficiaries (tax authorities or, in jurisdictions where payments cannot be made directly to the tax authority, a Fiscal Representative which is obliged to pay the tax authority) 
  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 
  • Marketing services providers. 

Processing of personal information by these third parties is only carried out under our instruction and for the purposes set out in this policy. We make sure that our third party suppliers always store Personal Data securely, delete it when no longer needed and never use it for any other purposes. 

6.2 We may also disclose your personal information in the following circumstances: 

  • To Regulatory agencies e.g. HMRC, law enforcement or any other third parties where we have a legal obligation to do so; 
  • To credit reference agencies and any entities that assist in making credit decisions in order to reduce the prevalence of fraud 
  • To any potential buyers, transferees, merger partners or sellers and their advisors. 
  1. Transferring your data outside of the UK or European Economic Area

7.1 Desucla stores Personal Data on servers situated within the UK and the European Economic Area (EEA). However, when we have a business reason to do so, we may transfer Personal Data to either a subsidiary of Desucla or a reputable third party organisation outside the EEA. 

7.2 These countries may have lenient privacy laws and so the Personal Data they have may become subject to their country-specific laws and disclosure requirements e.g. to regulatory agents, private persons or governmental bodies. 

7.3 We have taken additional precautions to ensure all Personal Data is treated with sufficient protection and when transferred outside of the UK or EEA, is done so lawfully according to the legal requirements for the transfer of Personal Data outside of the UK or EEA. Your consent is required for such transfers or else standard contractual clauses as required by the UK ICO and European Commission as applicable. 

  1. Protecting your Personal Data

8.1 Desucla has implemented appropriate technical and organisational security policy measures in order to protect Personal Data, as well as sensitive Personal Data, from loss, misuse, alteration or destruction and to allow access to this data solely on a ‘need to know’ basis, including by the use of firewalls, anti-virus software and encryption. 

8.2 Furthermore, Desucla may administer anonymization, de-identification and pseudonymisation methods in order to enhance protection of your Personal Data. 

8.3 Where applicable, you hold responsibility for keeping your user ID and password secure. 

8.4 Whilst we endeavour to protect the security of your Personal Data, please note that the transfer of data by email or via the internet is never completely secure hence transmission is at your own risk. 

  1. Your Personal Data Rights

9.1 You have various rights in respect of the personal information we hold about you – these are set out in more detail below: 

  • Automated Individual Decision-making: You can request that we assess any decisions made about you based exclusively on your Personal Data which may have resulted in legal consequences; 
  • Confirmation: You can request confirmation as to whether we are processing your Personal Data and to provide more specific information if you so wish i.e. for what purposes, what types of data are collected, the recipients of the data, storage timeframes, third party sources in which it was obtained and any potential consequences of the data; 
  • Correction: If you ascertain that our records are incorrect, you can ask us to update your details; 
  • Data portability: You can request to have us transfer Personal Data which you have provided to us to another company, so long as this is in a structured, commonly used, electronic form and can be easily transferred.. 
  • Erasure: you can request to erase your Personal Data once we no longer require your information for the original purpose it was collected or you withdraw your consent to processing; 
  • Processing Restrictions: You can ask us to restrict our use of your personal information in the following circumstances: a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Right to Object: You can object to our processing of your personal information 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. You also have the right to object/opt-out where we are processing your personal information for direct marketing purposes. including profiling: However, we may need to keep essential data to observe your request of discontinuing our marketing to you;  
  • Right to Withdraw Consent: You may withdraw your consent given to process your Personal Data, however, this may mean we are unable to provide certain products and services to you; we will advise you if this becomes the case. 

9.2 If you wish to execute your Personal Data rights, please email?[email protected] Please note that you will need to provide us with evidence of your identity. 

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. 

9.3 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. 

  1. Third party websites

Our website may, from time to time, contain links to and from the websites of our third party partners, Fiscal representatives and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies and the terms and conditions of use before you submit any Personal Data to these websites. 

  1. Changes to our privacy policy

11.1 We systematically revise our Privacy Policy and will update this Privacy Notice accordingly in order to maximise our commitment in protecting and upholding your Personal Data rights. 

11.2 If significant changes are made to this policy, we will communicate this to you through our website, email or any other method of contact. 

  1. Who to contact regarding privacy concerns and queries

If you wish to give feedback concerning this policy, have a complaint or would like to exercise any of your Personal Data rights, please contact?[email protected]. Where the information has been provided to us by a third party partner with whom you are contracted for tax payment services, please contact the, directly too. 

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: 

ICO website: https://www.ico.org.uk; helpline number: 0303 123 1113. 

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. 

Last Updated: 1 June 2023