Privacy Policy

Welcome to Submitandgo Ltd's Privacy Notice

Submitandgo Ltd respects your privacy and is committed to protecting your personal data. This privacy notice explains how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

Purpose of This Privacy Notice

This notice explains how Submitandgo Ltd collects and processes your personal data through your use of this website, including data you provide when you sign up to our newsletter, purchase a product or service, take part in live chat or report a problem on our site. This notice also applies to the Submit&GO platform (app.submitandgo.com) and to any personal data we process when you use it.

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

Please read this notice together with any other privacy or fair processing notice we may provide on specific occasions. This notice supplements those notices and is not intended to override them.

Controller

The data controller is Submitandgo Ltd (Company No. 10096069), 171 Kingston Road, Teddington, TW11 9JP. We have appointed a data protection officer (DPO), responsible for questions about this notice. Our DPO is Mr Attila Cseko. If you have any questions or wish to exercise your legal rights, please contact Mr Attila Cseko at support@submitandgo.com.

You have the right to make a complaint at any time to the UK supervisory authority, the Information Commissioner's Office (ICO): www.ico.org.uk . We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us first.

Changes to This Notice & Your Duty to Inform Us

Data protection laws in the United Kingdom, including the UK GDPR and the Data Protection Act 2018, set out your rights and our obligations in relation to your personal data. This notice reflects those requirements and will be updated from time to time to ensure ongoing compliance with legal or operational changes.

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.

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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. It does not include data where identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:

• Identity Data - first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data - billing address, delivery address, email address, telephone numbers.
• Financial Data - bank account and payment card details.
• Transaction Data - details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data - IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data - your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data - information about how you use our website, products and services.
• Marketing and Communications Data - your preferences in receiving marketing from us and our third parties and your communication preferences.
• Bank Transaction Data - where you choose to connect a bank account: account name, sort code and account number (or masked equivalents), balances and transaction details (date, amount, description, payee/payer).
• Tax Data - Unique Taxpayer Reference (UTR), National Insurance number, VAT registration number, company number, tax periods, obligations and the figures you prepare or submit to HMRC.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect information about criminal convictions and offences.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

• Direct interactions - You may give us Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services; create an account; subscribe to our service or publications; request marketing; enter a competition, promotion or survey; or give us feedback.
• Automated technologies or interactions - As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns through cookies, server logs and similar technologies. We may also receive Technical Data if you visit other websites employing our cookies. Please see our Cookie Policy for details.
• Third parties or publicly available sources - We may receive personal data about you from analytics providers (e.g., Google), advertising networks, search information providers; payment and delivery service providers; data brokers/aggregators; and publicly available sources such as Companies House and the Electoral Register (UK). We do not currently use analytics or advertising cookies; if this changes, we will update this notice and our Cookie Policy.
• Open Banking - If you connect a bank account, we receive your Bank Transaction Data through a regulated Open Banking provider, only with your explicit authorisation given directly to your bank. Access is read-only: we cannot move money or make payments. Authorisation is time-limited, and you can withdraw it at any time in the app or with your bank.
• HMRC - When you authorise Submit&GO to connect to HMRC, we exchange data with HMRC (for example, obligations and submission receipts) on your behalf.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we use it to perform a contract with you, where it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests), or where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis other than for sending third-party direct marketing by email or SMS (which you can withdraw at any time).

Purposes for Which We Will Use Your Personal Data

• Register you as a new customer - (a) Identity, (b) Contact. Legal basis: performance of a contract.
• Process and deliver orders - (including managing payments/fees/charges and collecting money owed) - (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing & Communications. Legal basis: performance of a contract; legitimate interests (recover debts due to us).
• Manage our relationship with you - (notifying you of changes to terms/privacy, asking for reviews or surveys) - (a) Identity, (b) Contact, (c) Profile, (d) Marketing & Communications. Legal basis: performance of a contract; compliance with legal obligations; legitimate interests (keep records updated, study how customers use our services).
• Run prize draws, competitions or surveys - (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing & Communications. Legal basis: performance of a contract; legitimate interests (develop services and grow our business).
• Administer and protect our business and website - (troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting) - (a) Identity, (b) Contact, (c) Technical. Legal basis: legitimate interests (running our business, IT services, security, fraud prevention, reorganisation); compliance with legal obligations.
• Deliver relevant content/ads and measure effectiveness - (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing & Communications, (f) Technical. Legal basis: legitimate interests (develop services, grow our business, inform marketing strategy).
• Use data analytics - to improve our website, products/services, marketing, customer relationships and experiences - (a) Technical, (b) Usage. Legal basis: legitimate interests (define customer types, keep our website relevant, develop business, inform marketing strategy).
• Make suggestions and recommendations - about goods or services that may be of interest - (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile. Legal basis: legitimate interests (develop services and grow our business).
• Provide bookkeeping features from your bank feed - (import and categorise transactions) - (a) Bank Transaction, (b) Financial. Legal basis: performance of a contract.
• Prepare and submit returns to HMRC under Making Tax Digital - (a) Identity, (b) Contact, (c) Tax, (d) Financial. Legal basis: performance of a contract; compliance with legal obligations.
• Send HMRC fraud prevention headers - (a) Technical (device identifier, IP address, screen and browser details). Legal basis: compliance with legal obligations (HMRC requires this data for all Making Tax Digital submissions).

Marketing

We strive to provide you with choices regarding personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may interest you (marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out.

Third-Party Marketing

We will get your express opt-in consent before sharing your personal data with any company outside Submitandgo Ltd for marketing purposes.

Opting Out

You can ask us (or third parties) to stop sending you marketing messages at any time. Where you opt out of marketing, this will not apply to personal data provided as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more details, see our Cookie Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason that is compatible with the original purpose. If you want an explanation as to how the processing for the new purpose is compatible, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis. We may process your personal data without your knowledge or consent where required or permitted by law.

Accountants, Agents and Their Clients

Where an accountant, bookkeeper or tax agent uses Submit&GO to manage their clients' records, that firm is the controller of its clients' personal data and Submitandgo Ltd acts as its processor, processing that data only on the firm's instructions. This includes firms connected to us, such as ACS Liberty Group Ltd, ACS Bookkeeping Services Ltd and ACS Liberty Group UK Ltd. If you are a client of such a firm, please contact the firm first about your personal data.

Disclosures of Your Personal Data

We may share your personal data with the following, for the purposes set out above: service providers acting as processors (IT, system administration, payments, hosting, analytics, communications); professional advisers (lawyers, bankers, auditors, insurers); HM Revenue & Customs, regulators and other authorities who require reporting; and third parties to whom we may choose to sell, transfer, or merge parts of our business. If a change happens, the new owners may use your personal data in the same way as set out in this notice.

Our key service providers include Amazon Web Services (email delivery), Cloudflare (website hosting and security), Microsoft (business email) and a regulated Open Banking provider (bank feeds). We require all service providers to keep your data secure and to use it only on our instructions.

International Transfers

Some of our service providers process data outside the UK, including in the EEA and the United States. Where this happens, we ensure the data is protected by a UK adequacy regulation, the UK International Data Transfer Agreement or Addendum, or the UK Extension to the EU-US Data Privacy Framework.

Data Security

We have put in place appropriate security measures, including encryption in transit and access controls, to prevent your personal data from being lost, used or accessed without authorisation. Access is limited to those who need it. We have procedures to deal with any suspected data breach and will notify you and the ICO where we are legally required to do so.

Data Retention

We keep your personal data for as long as you have an account with us and, after that, for up to six years to meet legal, tax, accounting and reporting requirements. Bank feed access ends when you disconnect your bank or close your account.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the rights to access, rectify, erase, restrict processing, object to processing, and data portability, as well as the right to withdraw consent where we rely on consent. To exercise any of these rights, please contact us at support@submitandgo.com.

You will not usually have to pay a fee to exercise your rights. However, we may charge a reasonable fee, or refuse to comply, if a request is clearly unfounded, repetitive or excessive. We may need to confirm your identity before responding. We aim to respond within one month; this may be extended by up to two further months if a request is complex or you have made a number of requests, in which case we will tell you.