Privacy Policy

This privacy policy sets out how Detox Reboot Ltd trading as Reth!nk.tax uses and protects your personal data.

1. Important information and who we are

This privacy policy gives you information about how Reth!nk.tax collects and uses your personal data through your use of this website, enquiring about our services and/or becoming our client/purchasing of our services.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Reth!nk.tax is the controller and responsible for your personal data (collectively referred to as Reth!nk.tax, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (section 11), please contact the DPO using the information set out in the contact details section (section 12).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. What personal data we may collect, use, store and transfer depends on the circumstances in which we interact with you.

We have grouped the broad types of personal data that we may collect, use, store and transfer below and set out which circumstances in which such data may be relevant:

Where you are, or work for, a customer of ours:

We will collect and process the following data from our website’s contact form or when you get in touch with us to make an enquiry

• Identity Data, which includes first name and last name.
• Financial Data, which includes your payment details (including your billing address or bank details, as appropriate).
• Contact Data, which includes address (home, postal or other physical address), email address and telephone numbers.
• Transaction Data, which includes details about payments to and from you and other details of services you have purchased from us.
• Marketing and Communications Data, which includes your preferences in receiving marketing from us and other third parties and your communication preferences.

Where you access our website rethinktax.co.uk or enquire about our services:

• Identity Data, which includes first name and last name.
• Contact Data, which includes email address and telephone number.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Usage Data includes information about how you interact with and use our website, products and services.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

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

Your interactions with us. You may give us your personal data by filling in online forms, engaging with our online chat service, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you enter into a contract with us for the provision of our services.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from third parties such as analytics providers (we currently use Google analytics).

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

5. Purposes for which we will use your personal data

We will only use your personal data when the law allows us to. We may collect and process the personal data about you for the following purposes:

Where you are, or work for, a customer of ours:

Provide and maintain our services – we will use your Identity, Contact, Financial and Transaction Data in order to process and deliver services to you, including provision of tax advice, the management of payments, and to inform you of changes to our services.
Contacting us – when you contact us with an enquiry or to request information, we will use your Identity and Contact Data to respond to you.
Advertising, marketing and public relations – we may use the Identity, Contact, Technical, and/or Usage Data of our customers to form a view on what we think our customers may want or need, or what may be of interest to them and in doing so we will only send information that is deemed relevant to their use of our services.
Administration – we may use your Identity, Contact and Technical Data for the purpose of protecting and operating our business, including customer support and/or hosting of data.
Where you are our customer, we process your personal data for the purposes of performing or entering a contract with you.

Where you are our customer or work for a customer, it is in our legitimate interests to process your personal data to run our business and provide services to you/your employer, keep our records updated and promote our business (for example in relation to marketing activities).

We may also have to process your personal data as it is necessary to comply with a legal obligation (for example, record keeping for tax and accounting purposes).

Where you access our website rethinktax.co.uk or enquire about our services:

Contacting us – if you contact us to our enquire about our services (or for any other purpose), we will process your Identity Data and Contact Data in order to deal with your enquiry and communicate with you.
Administration – we may use your Technical Data and Usage Data for the purpose of protecting our business and our website, including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data.
Website Analytics – as you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve the content of the website and to customise the content or layout of the website for you, in accordance with our legitimate interests.
This is necessary for our legitimate interest. Where it is in relation to contacting us, our legitimate interest is in dealing with enquiries and furthering our business interests. Where it is for administration, our interest is in running our business and for compliance with our legal obligations. Where it is for website analytics, our interest is in keeping our website updated and relevant, to develop our business and to inform our marketing strategy.

Where personal data is collected via cookies (see section 6 below), we will seek your express consent for the use of those cookies.

Other circumstances:

We may also use personal data which you provide to us, where the law allows us to do so, where we need to comply with a legal or regulatory obligation, including the prevention of crime.

For clarity, where we rely on our legitimate interests to process personal data we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

6. Cookies How do we use cookies on our website

Our website uses limited cookies to distinguish you from other users of our website and provide analytics data to us. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our sites.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. A cookie will typically contain a record of the website which issued it, its own name, and a value which is often a randomly generated unique number. A cookie will have a ‘lifetime’, which tells your browser when to delete it.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services.

Cookie Types

Different cookies are used for different purposes. The most common ones are as follows:

Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Cookies We Use

The table below provides an overview of the cookies used on our main website (https://rethinktax.co.uk/), including details of who sets each cookie, its purpose, when it expires, and, if relevant, how you can find out further information.

Cookie	Purpose	Duration
_ga	Analytical cookie – used for Google analytics to distinguish one visitor from another	2 Years
_ga_20JVF761KN	Analytical cookie – used for Google analytics to distinguish one visitor from another	2 Years
ar_debug	Analytical cookie – used by Google Ad Services to debug ads	1 Years

Declining Cookies – Your Choice

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer and you can also view and/or delete cookies already on your computer although this will depend on the particular web browser that you use.

Please note that some cookies can be essential to the effective functioning of some of the services we offer online. If you disable cookies, a number of important functions and services will be unavailable to you and our websites may not operate correctly in your browser

 

7. Disclosures of your personal data

Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:

• On occasion, we need to hire other companies to help us to serve you better, and in some of these cases we may need to share personal data that is necessary for such third parties to perform tasks for us including but not limited to when we share your personal data with third party contractors through the Vendor Portal on our CRM system (currently Zoho).
• Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
• Where we are under a legal duty to do so in order to comply with any legal obligation.
• In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
• If we or substantially all of our assets are acquired by a third party, in which case personal data that we hold about our customers will be one of the transferred assets.

We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

8. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that specific safeguards are in place.

In particular, we will only transfer your data outside of the UK if the jurisdiction it is transferred to either:

• Has been deemed by the relevant authority to have an adequate level of protection for your personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us.

 

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, 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. They will only process your personal data on our instructions and they 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.

 

10. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see section 11 below for further information.

 

11. Your Rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: o If you want us to establish the data’s accuracy; o Where our use of the data is unlawful but you do not want us to erase it; o 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 o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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 is a security measure to ensure that personal data is not disclosed to any person who has 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

 

12. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO by email at support@rethink.tax

 

13. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

14. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 17 September 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

 

15. Third-party links

This 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 data about you. 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 policy of every website you visit.