Policy Statement
Sovereign Plus Limited (‘we’, ‘us’, and ‘our’) take data protection very seriously and we are committed to protecting your personal information.
Should we ask you to provide certain information by which you can be identified when using our services, you can be assured that it will only be used in accordance with this privacy policy.
This privacy policy sets out how Sovereign Plus Ltd uses and protects any information that you give to us, but should you have any further questions, please contact us.
Sovereign Plus Ltd may change this policy by updating this page. You should check this page occasionally to ensure that you are happy with any changes.
It is our policy to only collect the minimum information required from you. If you believe we have collected excessive information about you, please contact us to raise any concerns you may have.
It is your choice to provide your personal information to us, however if you do not wish to provide personal information, we may be unable furnish you with the information, advice or services you want from us.
Once you become a customer of Sovereign Plus Ltd, we will assign you a customer unique identifier number. This is a legitimate activity in order to avoid any system errors or mistakes in making payments.
We will send you tax and VAT updates and useful information as part of our contractual service with you.
Topics covered in this document:
- What is personal information?
- Collecting Personal Data
- What data do we collect?
- How do we collect your data?
- Using Personal Data
- Legal grounds for processing personal information.
- How do we protect your data?
- Sharing personal information
- Other disclosures
- International transfers of personal information
- Retention of personal information
- Marketing
- What are your data protection rights?
- How to contact us
What is personal information?
Personal information is anything that enables you to be identified or identifiable, such as your:
- First and last names
- Postal and email addresses
- Telephone numbers
- Identity documents (e.g., passports & driving license)
- Identity numbers (e.g., National Insurance and Bank accounts)
- Unique Tax Reference number (UTR, verification for tax and CIS)
- Contact information.
In addition, we may collect personal information from other sources:
- Publicly accessible sources, e.g., Companies House, HM Land Registry, a company website, or bankruptcy searches
- Client due diligence and sanctions screening providers
- A third party with your agreement, e.g., your financial adviser or your doctor
What data do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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 and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 any information about criminal convictions and offences.
How do we collect your data?
You directly provide Our Company with most of the data we collect. We collect data and process data when you:
- Register online or place an order for any of products or services we provide.
- Use or view our website via your browser
If you are a self-employed subcontractor using our services, we may be passed your name and telephone number from our clients and be asked to contact you. Our clients will have confirmed that they have the relevant consents and authority to do so from you and we have a contract in place with our clients to this effect. We shall contact you following receipt of this information as we have a legitimate interest to do so.
Using Personal Information
When you provide personal information to us, we may use it for any of the purposes described below or as stated at the point we collect it from you (or as may be obvious to you from the context of collection), including:
- To provide advice and services you have requested.
- To manage our practice
- To complete statutory returns
- To comply with our legal and regulatory obligations
- To consider whether to offer someone employment with us.
- To administer and manage our website.
- To understand how people, use the features and functions of our website in order to improve the user experience.
- Any other purposes for which personal information has been provided to us, including any of the purposes given in the ‘Collection of personal information’ section above.
- We do not collect personally identifying information for sale to third parties.
Legal grounds for processing personal information
We rely on one or more of the following processing conditions:
- To perform our contractual obligations to you; and/or
- To satisfy any legal and regulatory obligations to which we are subject; and/or
- To satisfy our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (where this does not interfere with your rights); and/or
- When you have agreed to us processing your personal information.
How do we protect your data?
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.
Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure.
We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Sharing personal information
We may transfer, share or disclose the personal data we collect from you to third parties.
- HMRC for the purpose of providing your chosen services and responding to requests for information
- National Crime Agency, Action Fraud and any other competent and authorised body for the prevention, detection and investigation of money laundering, fraud or terrorist financing
- The Financial Conduct Authority (FCA) for the purposes of any business activity regulated by the FCA (including Consumer Credit and Money Services)
- The Financial Ombudsman Service (FOS) to resolve any complaint or dispute involving the FOS
(other organisations or individuals) for:
- The purposes for which the information has been submitted.
- The purposes listed above under ‘Use of personal information.’
- The administration and maintenance of our website and/or
- Other internal or administrative purposes
We also may transfer, share, or disclose personal data to third party service providers of identity management, website hosting and management, data analysis, data backup, security and storage services.
These third-party providers may use their own third-party sub-contractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub processors.
Other disclosures
We may also disclose personal information to third parties under the following circumstances:
- When explicitly requested by you
- When required to deliver goods or services requested by you
- When required to facilitate our conferences or events that you have asked to attend which are hosted by a third party
- As otherwise set out in this privacy policy.
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation.
Retention of personal information
We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law.
Normally, this means we will retain your personal information for at least 6 years.
For business records, we may keep your data for 5 years if a sole trader or partner and 6 years for companies.
Marketing
On the occasion our company sends information about products and services of ours that we think you might like, we will only do so if you have agreed to receive marketing, you may always opt out at any time.
Where we are legally required to obtain your consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.
We may ask for feedback on our products or services in order to monitor and improve our service delivery, and this is a legitimate activity for us. You can complete these questionnaires if you wish to, however you are not obliged to do so. These questionnaires are not anonymous.
You have the right to unsubscribe to marketing at any time. If you do choose to unsubscribe, we will keep your name and email address on a suppression list so that we don’t email you again by accident and this is a legitimate activity for us.
If you are on our suppression list, you will still receive communications that are necessary to the performance of your chosen services, or notifications to avoid you missing deadlines and/or incurring penalties.
What are your data protection rights?
Our company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access: You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification: You have the right to request we correct any information you believe is inaccurate. You also have the right to request our company to complete information you believe is incomplete.
The right to erasure: You have the right to request we erase your personal data, under certain conditions.
The right to restrict processing: You have the right to request we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our company’s processing of your personal data, under certain conditions.
The right to data portability: You have the right to request that our company transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
How to contact us
We try to be as open as we can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal data by making a ‘Subject Access Request’ (SAR). There is no charge for such a request and we will respond within 30 days of a verified* request. If we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding it
- Tell you who it could be disclosed to
- Let you have a copy of the information in an intelligible form
If you make a request, we have one month to respond to you. Occasionally it may 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.
If you would like to exercise any of these rights, please contact us:
Email us on: info@sovereignplus.com
Call us at: +44 (0) 2392 800686
Or write to us: Unit 6 St George’s Square, Portsmouth, England, PO1 3EY
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (please note we cannot be responsible for the content of external websites)