DRAFT — needs solicitor review. This is a working template. You must confirm the data-controller identity, hosting regions, retention periods, and complete every [bracket] before publishing. You may also need to register with the ICO.

Privacy Policy

Last updated: [DATE]

1. Who we are

Quarterly (“we”, “us”) is operated by [YOUR LEGAL NAME / COMPANY], [ADDRESS]. We are the “data controller” for the personal data described here. Contact: [CONTACT EMAIL]. [If registered with the ICO, add registration number.]

2. What we collect

3. How we use it and our lawful bases

PurposeLawful basis (UK GDPR)
Provide the record-keeping and submission servicePerformance of a contract
Submit quarterly updates and fraud-prevention data to HMRCContract + legal obligation (MTD)
Read receipt images with AI to suggest a categoryConsent / legitimate interests
Security, audit trail, fraud preventionLegitimate interests / legal obligation
Account and service emailsContract

4. Who we share it with (processors & recipients)

We do not sell your data.

5. International transfers

Some providers above may process data outside the UK. Where they do, appropriate safeguards (such as UK/EU approved transfer mechanisms) apply. [Confirm and describe.]

6. How long we keep it

We keep your records for as long as your account is active and as needed to provide the Service. Because MTD requires durable records, submission and audit entries are retained for [X years / in line with HMRC’s record-keeping requirements]. You can ask us to delete your account data, subject to legal retention obligations.

7. Your rights

Under UK GDPR you can request: access, correction, deletion, restriction, portability, and to object to certain processing, and you can withdraw consent (e.g. to AI processing) at any time. To exercise these, contact [CONTACT EMAIL].

You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

8. Security

We use per-user access controls (row-level security), a private receipt-image store, and server-side handling of HMRC tokens. No system is perfectly secure, but we take reasonable measures to protect your data.

9. Cookies & local storage

We use only what the app needs to work: your sign-in session and a device identifier used for HMRC’s fraud-prevention headers. Vercel Web Analytics is cookieless. We do not use advertising cookies. [Add a cookie notice/banner if this changes.]

10. Children

The Service is for adults managing their own tax affairs and is not directed at children.

11. Changes & contact

We may update this policy and will notify you of material changes. Questions: [CONTACT EMAIL].

See also our Terms of Service. · Back to Quarterly