AVS VAT is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This policy sets out how we collect and use your personal information during and after your relationship with us.
We take the privacy and security of our clients and contacts very seriously. We never sell your data and we promise to keep your details safe and secure. We will only use your personal information to administer your account and to provide the products and services you have requested from us and to stay in touch in accordance with your Contact Consent in Appendix 3.2.
While information relating to your business is not classified as personal information, we do collect, store and use personal information in order to enable us to fulfil our Anti Money Laundering (‘AML’) obligations and also to provide you with the requested services. Personal information is any information about an individual from which that person can be identified (not including information where the identity has been removed). This includes:
- Your full name, title, gender, marital status and dependents, telephone numbers and personal email addresses
- Your home address/es over the last 3-years
- Your date of birth
- Your National Insurance Number, Passport Number and/or driving licence, bank account details, salary, emoluments and tax status information
We collect this information either directly from you or sometimes indirectly from third parties such as accountants or solicitors. We will collect additional personal information in the course of job-related activities throughout the period in which we supply the services to you. If you are supplying us with personal information for or on behalf of your customers or clients, you must ensure that you have their consent to do so and shall indemnify us against all liabilities, costs, expenses, damages and losses and all other reasonable professional costs and expenses suffered or incurred by us arising out of or in connection with your failure to obtain the same.
We will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you
- Where we need to comply with a legal obligation
- 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
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests)
- Where it is needed in the public interest or for official purposes
We may have to share your personal information with third parties, including regulators, AML verification organisations or third-party service providers where it is required by the law, necessary to provide the services or where we have another legitimate interest in doing so. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies to respect the security of your personal information and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
We will only retain your personal information 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 information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
For monitoring our website we use server log files and third-party statistical services to help analyse how visitors find and use the site. We do not use the logs or statistical services to track or to collect any personally identifiable information of visitors to this site.