GDPR 

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PRIVACY POLICY

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Cryptocountancy Ltd (CC) are committed to protecting and respecting your privacy.

This notice together with our Data Protection Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. 

Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.

Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

Our nominated Data Protection representative is Zac Marks and can be contacted at hodl@cryptocountancy.co.uk

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1. Information you give to us or we collect about you

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This is information about you that you give us by filling in forms on our site www.cryptocountancy.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, apply to a vacancy, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. 

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Your personal data will be stored on our servers. Your data can only be accessed by our employees and thus are obliged to comply with GDPR when processing your personal data, provided you reside in the European Union.

We may furthermore disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets. Furthermore, we may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of CC, our customers, or other parties.

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2. Which personal data CC collects

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CC only collects personal data to help us with the services you require and would typically collect the following personal data:#

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• Your full name

• Your registered address

• Your date of birth

• Your email addresses

• Your (mobile) telephone number

• Your website

• Your passport/visa, when requested by the client

 

3. How CC collects personal data

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CC collects your personal data in the following ways:

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1. You complete a ‘Contact us’ form or register with CC on our website

2. We have received your details about you from another third party, for instance; a business contact, a client or professional advisors

3. You have met or spoken with a Cryptocountancy Consultant and are sharing information by email to CC

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When CC receives your details in one of the above ways we save your information provided by you on our CRM system. Your information.

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4. Why we hold your data and legal basis

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CC will collect your information to carry out our core business and ancillary activities – for the purpose of accounting services. In particular, CC will collect and process your personal data for the following purposes:​

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• Keeping your personal data on file for purposes of filing returns

• If we ask for a copy of your ID, National Insurance number, proof of address 

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5. The following legal basis applies for processing your data if we have been in touch with you within the last three years:

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• We will process your data as we believe that we have legitimate interests to do so.

• We have carried out a three-part test (a so-called legitimate interest’s assessment).

• As we thus need to satisfy our client’s resourcing needs we require an up-to-date database. We always ask for your permission before we process any of your sensitive data (e.g. passport copy or references). In practice, we would acquire this type of information only upon request.

• Thus, to maintain, expand and develop our business we need to record the personal data of our (prospective) clients who have been in touch with CC within the last three years. We have chosen this three-year period as it is likely that (1) there is a(n) ongoing relationship between you and CC  (2) your data on our database is still up-to-date. We have also chosen this three-year period as we think this timeframe is regarded to be industry standard.

 

6. The following legal basis applies for processing your data if we have not been in touch with you within the last three years:

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If you have not been in touch with us for the last three years, we understand that the data (1) we hold on file may be inaccurate (2) you may not be interested in getting contacted by CC anymore.

We will, therefore, process your personal data only if you have given your consent for us to do so. We will request your consent by an online process for the specific activity we require consent for and record your response on the system. If you haven’t already done so, to opt in any email communications from us, please click the ‘subscribe’ link.

You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To opt out of any data processing and/ or email communications from us, please click the ‘unsubscribe’ link at the foot of the email in question for an immediate removal from our database and /or further communications.

Furthermore, if you previously agreed to us holding or using your personal information, you may change your mind at any time by accessing the preference centre to change your settings. Alternatively, you can email hodl@cryptocountancy.co.uk We will process the restriction of use in our marketing communications or removal of your personal information within 30 working days.

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7. How long will we store your data?

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Your personal data will be stored in our systems for three consecutive years. 

Your data will be removed from our systems if:

1. We have not heard from you during a period of three years, or

2. If you request for your data to be removed

Different retention periods apply if

1. you have entered into an agreement with CC for which a different Data Processing Notice applies

2. unless there is a direct statutory requirement (that comes into force) under which CC is obliged to keep your data stored in our internal databases for another period of time.

 

8. What are your rights under GDPR

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Under GDPR you are entitled to various rights:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our accountants, make sure you notify us of any changes or update your information like email, phone number etc. when they change.

• You can request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). This means should you wish to be removed from CC's database, please email hodl@cryptocountancy.co.uk We will review and process your request within 30 days.

• You can object to the 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 where we are processing your personal information for direct marketing purposes.

• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• You can request the transfer of your personal information to another party in certain formats, if practicable.

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CC will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, CC may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

 

9. Automated decision making, including profiling

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CC will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular, to analyze or predict aspects concerning your personal preferences, We will not make decisions that are based solely on automated processing which produces legal effects, or similarly significantly affects you as a data subject.

 

10. Lodging a complaint

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If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the national supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to contact us via hodl@cryptocountancy.co.uk

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11. Changes to this Data Processing Notice

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Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.