Privacy notice

1 · Introduction

This policy relates to your personal information in connection with your use of rethink.tax (the Platform) and any services we provide (together, the Services). If you have questions or concerns about this policy or our practices, contact us at support@rethink.tax. If there are terms here you do not agree with, please discontinue your use of the Services.

2 · Changes to this policy, and to your information

We review this policy regularly; please check it periodically. Where we make significant changes we will use reasonable endeavours to tell you in advance, in writing. It is important that the information we hold about you is accurate and current - please tell us if it changes.

3 · About us

The Services are owned and operated by Detox Reboot Ltd (trading as Reth!nk.tax), registered in England and Wales, company number 09538143, registered office 4th Floor, 100 Fenchurch Street, London, EC3M 5JD. Reth!nk.tax is the controller of, and responsible for, your personal information.

4 · Information we may collect

Information you give us. Your name, address, contact details, date of birth, job title and payment card information, provided when you register, use the Services, or otherwise contact us. If you apply for a role with us we also collect contact details, financial and payment details, education, qualifications and skills, marital status, nationality, National Insurance number, job title and CV.

If you give us information about another person - an emergency contact, referee or next of kin - you confirm you have their permission to do so.

We gather information face to face, by telephone, through the Platform, and when you request information, report an issue or give feedback. We may monitor and record communications for quality, training, fraud prevention and legal compliance. If you visit our offices, some data may be collected by CCTV.

Categories. Identity data · contact data · financial data (card details are processed and stored by a contracted third-party payment provider, not by us) · transaction data · profile data · usage data · marketing and communications preferences.

Sensitive information. We will not usually ask for it. If we do, we will explain why and how it will be used, and we will only collect it with your explicit consent.

From third parties. We may occasionally receive information about you from other sources and add it to what we hold, to provide and improve the Services. If you apply for a job we may receive references.

Collected automatically. IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location and other technical information. This is needed to maintain security and operation, and for internal analytics.

5 · How we use your information

We process your information in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and to comply with our legal obligations.

Purposes include: taking steps toward a contract and providing the Services; preparing agreements; managing your account; contacting you about the Services; following up enquiries; contacting your next of kin or emergency contact where we cannot reach you; taking references; dealing with payment; notifying you of changes; resolving disputes; recruitment; sending administrative information; sending marketing where you have consented; account creation and log-in; administering promotions; requesting feedback; protecting the Services and preventing fraud; enforcing our terms; responding to legal requests; and analysis to improve what we do.

6 · Sharing your information

We share and disclose your information only where necessary to perform a contract, to fulfil our business purposes, or with your consent. That includes: providers and partners enabling products or services; disclosure required by law, court order or public authority; where necessary to investigate or prevent potential violations, suspected fraud or threats to safety; third-party vendors, service providers, credit reference agencies, trade associations, contractors and agents who need access to perform services - including lawyers, tax advisers, accountants, trust companies, lenders and brokers - who must keep it confidential and use it only as we direct; business transfers in connection with a merger, sale or acquisition; business partners where you have consented; and any other purpose with your consent.

We may disclose aggregated, anonymous information from which you cannot be identified.

7 · International transfers

Where we transfer information outside the UK we take all reasonably practicable measures to protect it in accordance with this policy and applicable law, transferring only to countries deemed to provide adequate protection or under UK-approved contractual safeguards. Contact us for details of the mechanism used.

8 · Third-party websites

The Platform may link to third-party sites or social channels not affiliated with us. We cannot guarantee the safety and privacy of data you provide to them, and their data is not covered by this policy. Review their policies and contact them directly with questions.

9 · How long we keep your information

We keep it only as long as necessary for the purposes set out here, unless a longer period is required or permitted by law - tax, accounting or other regulatory requirements. When there is no ongoing purpose we delete or anonymise it, or where that is not possible (for example in backup archives) we store it securely and isolate it from further processing until deletion is possible.

10 · Keeping your information safe

We have implemented appropriate technical and organisational security measures, and store personal data on secure servers. We have procedures for suspected breaches and will notify you and any applicable supervisory body where legally required. We cannot guarantee the internet itself is secure; transmission is at your own risk.

11 · Children

We do not knowingly solicit data from or market to anyone under 16. By using the Services you represent that you are at least 16. If we learn we have collected data from someone younger, we will deactivate the account and delete the data. Tell us at support@rethink.tax if you become aware of any.

12 · Consent

Where consent is required we will seek it when you first submit information. You may withdraw consent at any time by emailing support@rethink.tax or using the unsubscribe link in mailings. If we have no other lawful basis we will stop processing. If we need to process your information for you to use the Services and you object, the Services may no longer be available to you.

13 · Marketing and opting out

Where you have consented we may contact you about our products, services and offers. Withdraw at any time by emailing us or unsubscribing. Where you have consented to sharing with selected third parties, contact those parties directly to withdraw. Opting out of marketing does not apply to data provided in connection with a purchase or transaction.

14 · Your profile

You may review or change your profile information at any time. To close it, contact support@rethink.tax. Some information may be retained to prevent fraud, troubleshoot, assist investigations, enforce our terms or comply with legal requirements.

15 · Your rights

You have the right to access a copy of the information we hold; to correction or completion where it is inaccurate or incomplete; to erasure in certain circumstances; to object to or restrict our processing in certain circumstances; and to data portability in a structured, commonly used, machine-readable format. Where we rely on consent, you may withdraw it at any time without affecting processing that happened beforehand.

We will require evidence of your identity before responding, as a security measure. To exercise or discuss any right, contact support@rethink.tax.

16 · Contact us

Questions or feedback on this policy: support@rethink.tax.

You have the right to complain at any time to the Information Commissioner's Office, the UK supervisory authority for data protection (ico.org.uk/concerns). We would appreciate the chance to address your concerns first.