Privacy Policy

 

1. Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.

This privacy notice applies to personal information processed by or on behalf of Evolution Accounting Limited.

Changes to this privacy notice

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – https://www.evolutionaccounting.co.im/

 

The Evolution Accounting Limited and our Data Protection Officer

We are Evolution Accounting Limited, Arcadia, Tynwald Road, Peel, IM5 1JP. We are a data controller of your personal data. The company which provides your product or service is named at the start of these terms and conditions.

We have a dedicated data protection officer (“DPO”), Mr Toby Smith. You can contact the DPO using the details below.

2. What kinds of personal information about you do we process?

Personal information that we’ll process in connection with all of our products and services, if relevant, includes:

• Personal and contact details, such as title, full name, contact details and contact details history
• Your date of birth, gender and/or age
• Your nationality, if needed for the product or service
• Family members (if relevant to the product or service)
• Records of your contact with us such as via the phone number of our business, or email or written correspondence
• Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
• The usage of our products and services, any services used
• Marketing to you and analysing data, including history of those communications, whether you respond to them or not.
• Information we obtained from third parties, including KYC information about you received from a business introducer such as personal identification and address verification documentation and other financial information as required to carry out our services
• Financial details about you, such as your salary and details of other income, details of your savings, details of your expenditure, and payment method(s)
• Details about all of your existing borrowings and loans, if relevant
• Information about your employment status, if relevant
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the Isle of Man or UK and/or whether you have the permanent right to reside in the Isle of Man or UK
• Your marital status, or family information, if relevant to the services provided (for example, for income tax purposes)
• Tax information, if relevant (for example, information on your savings accounts)

3. What is the source of your personal information?

We’ll collect personal information from the following general sources:

• From you directly, and any information from family members, associates or beneficiaries of products and services
• Information generated about you when you use our products and services
• As a result of our background checks undertaken as part of our client take-on and continuance procedures using amongst other methods, screening software

From other sources such as Fraud Prevention Agencies, Government bodies including the tax and VAT office and other regulatory bodies.

4. What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:

• Assessing an application for a product or service, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms
• Managing products and services relating to that the product or service, or application for one
• Updating your records, tracing your whereabouts and recovering debt
• Managing any aspect of the product or service
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To monitor and to keep records of our communications with you and our staff (see below)
• To administer our good governance
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers for ourselves, helping us improve products or services, or to assess or improve the operating of our businesses
• To facilitate the sale of one or more parts of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

1. Where it is needed to provide you with our products or services, such as:
   a) Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions to attach
   b) Managing products and services you hold with us, or an application for one
   c) Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
   d) All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts
2. Where it is in our legitimate interests to do so, such as:
   a) Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
   b) To perform and/or test the performance of, our products, services and internal processes
   c) To follow guidance and recommended best practice of government and regulatory bodies
   d) For management and audit of our business operations including accounting
   e) To carry out monitoring and to keep records of our communications with you and our staff (see below)
   f) To administer our good governance requirements such as internal reporting and compliance obligations
   g) Subject to the appropriate controls, to provide insight and analysis of our customers for our own use, helping us improve products or services, or to assess or to improve the operating of our businesses
   h) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
3. To comply with our legal obligations

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

• Business partners (for example, where we jointly provide services to you and it is necessary for the fulfilment of those services)
• Governmental and regulatory bodies such as HMRC or IOM Tax Office, the Financial Conduct Authority, the Financial Services Authority and the VAT authorities.

7. How and when can you withdraw your consent?

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

8. Is your personal information transferred outside the UK or the EEA?

We’re based in the Isle of Man but sometimes your personal information may be transferred outside the UK or European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.

10. Do you have to provide your personal information to us?

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

11. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

12. For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or

Retention periods in line with legal and regulatory requirements or guidance.

13. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: Isle of Man Information Commissioner. Head Office. PO Box 69. Douglas. Isle of Man. IM99 1EQ. Telephone: +44 1624 693260 https://www.gov.im/about-the-government/offices/isle-of-man-information-commissioner/

14. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.

Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, write to Evolution Accounting Limited, Arcadia, Tynwald Road, Peel, Isle of Man IM5 1JP, marking it for the attention of the DPO.