This website is owned and operated by Contexo Mobility & Tax Consulting Ltd (“we”, “us”, “our”, and “ourselves”), referred to hereafter as “Contexo Mobility”. Contexo Mobility is the data controller with respect to your personal data.
1. We Respect Your Privacy
Your privacy and security of your personal data is important to us. This policy describes how we collect, store, transfer, and use personal data. It tells you about your privacy rights and how the law protects you. In the context of the law and this policy, “personal data” is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as “processing”.
First and foremost, we are committed to safeguarding your privacy and personal data.
2. Periodic Update
We may change this policy from time to time by updating this page. You should check this page periodically to ensure you are happy with any changes. This policy is effective from January 2, 2023.
3. Personal Data We Collect
3.1. How we obtain personal data
The information we process about you includes information:
- you have directly provided to us
- that we gather from third parties such as databases, service providers, websites, and social media
- as a result of monitoring how you use our website or our services
3.2. What we collect directly
When you use our website or our services, we ask you to provide personal data. This can be categorized into the following groups:
- Personal Identifiers: Your first and last names, title, date of birth, national/state identification number, and taxpayer identification number such as US social security number
- Employment Information: Your job title, employer name, and locations of service
- Contact Information: Your email address, telephone number, and postal addresses for billing, delivery, and communication
- Personal Information About Other Individuals: Examples include information relating to your employees and/or contractors when you engage us to provide certain employer services where such information is pertinent
- Records of Communication Between Us: This covers correspondence between us and you by whatever means, including messages sent through our website, client portals, and email service as well as telephone conversations and video conferences.
- Subscription Preferences: Your preference for subscription of newsletters
In addition, we may process:
- Documentation that confirms your identity such as an image of your passport, driver’s license, national/state identity card, US social security card, and proof of address
- documentation that confirms your income, expenses, investment and financial holdings, and taxes, which may include legally required identifiers of your payors and payees
- information about business interests as well as activities and financial records of such interests related to you, your family, and certain US persons
- information about individuals and entities connected with you whom you authorize us and we agree to interact with in the course of our work
- other personal and financial details needed for tax preparation, representation, and tax consulting services
- other information relevant to client surveys and/or offers
- payment information such as bank account details
3.3. What we collect from third parties
We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes as part of our due diligence process.
The additional information we collect can be categorized as follows:
- publicly available information
- financial and tax information from persons and entities connected with you as well as relevant government agencies, with your authorization and our agreement
3.4. What we collect from your use of our services
By using our website and our services, we process:
- information used to access our website and our services
- information and documents used to provide our services
- information you contribute to our community, including reviews
- your replies to polls and surveys
- technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
- usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
- transaction information that includes the details of the products and services you have bought from us and payments made to us for those services
- your preferences to receive newsletters from us, how you wish to communicate with us, and responses and actions in relation to your use of our services.
4. Our Use of Aggregated Information
We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
For example, we may aggregate usage information to assess whether a feature of our website is useful.
5. Special Personal Data
Special personal data is data 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.
We may collect special personal data about you if there is a lawful basis on which to do so.
6. If You Do Not Provide Personal Data We Need
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 that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
7. The Bases on Which We Process Information About You
The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
7.1. Information we process because we have a contractual obligation with you
When you create an account on our website, purchase a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.
We may use it in order to:
- verify your identity for security purposes when you use our services
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services, and how to obtain the most from using our website
We process this information on the basis there is a contract between us or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
7.2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us in accordance with the process outlined in paragraph 10.6. Control over your own information. However, if you do so, you may not be able to use our website or our services further.
We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
7.3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so only after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- improving our services
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- preventing fraudulent use of our services
- exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
- insuring against or obtaining professional advice that is required to manage organizational or business risks
- protecting your interests where we believe we have a duty to do so
7.4. Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order.
This may include your personal data.
8. How and When We Process Your Personal Data
8.1. Your personal data is not shared
We do not share or disclose to a third party any information collected, except as otherwise mentioned in this policy.
8.2. Payment information
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of PayPal, Stripe, or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
8.3. Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
8.4. Referral partners
This is information given to us by you in your capacity as an affiliate of ours or as a referral partner.
It allows us to recognize visitors that you have referred to us. The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
9. Use of Information We Collect Through Automated Systems
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalized experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility, record how you interact with the website so that the owner can understand how to improve the experience of other visitors, and serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in to our website
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
9.2. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider, and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
10. Other Matters
10.1. Your rights
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
We do this now, by requesting that you read the information provided at https://www.knowyourprivacyrights.org
10.2. Use of our services by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian.
We collect data about all users of and visitors to these areas regardless of age. While we neither verify nor have a liability to verify the age of our users, we will delete data submitted by children under the age of 18 and not use such data for any purpose, to the extent we become aware of its existence.
10.3. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt the transmission of any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
10.4. Third-party service providers
We may use third-party service providers, through which your personal data is processed, where it is necessary in the provision of services to you or for administrative purposes or where we have another legitimate reason in doing so.
Where we correspond with you, such communication which may contain personal data is stored on secure servers maintained by Verifyle for secure client portal and Proton AG for email service. Through these encrypted channels, we provide you the means to share your personal and sensitive data with us securely.
All of our third-party service providers take commercially reasonable and appropriate security measures to protect your personal data. Verifyle and Proton Mail are both GDPR complaint. Comprehensive information about these third-party service providers’ compliance and certification status as well as their security policies and privacy statements can be found on their websites:
- Verifyle: https://verifyle.com/compliance.html
- Proton Mail: https://proton.me/business/gdpr
If you use our encrypted client portals or email service to transmit data to or from us, you may be required to set a user name and password directly with our third-party service providers. Data supplied in setting these up will be held by the respective providers and dealt with in accordance with their privacy policies.
10.5. Data may be processed outside the UK
Our websites are hosted in the United States. We may also use third-party service providers in countries outside the UK from time to time in various aspects of our business, particularly for professional US tax preparation software and secure client portal due to our specialization in US expatriate tax. Accordingly data obtained within the UK or any other country could be processed outside the UK.
We use the following safeguards with respect to data transferred outside the UK:
- the processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing
- the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority
- we comply with a code of conduct approved by a supervisory authority
- we are certified under an approved certification mechanism as provided for in the relevant laws, regulations, and guidelines
10.6. Control over your own information
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.
At any time, you may contact us to request that we:
- provide you with the personal data we hold about you;
- review or update personally identifiable information that we hold about you; or
- remove your personal data.
When we receive any request to access, edit, or delete personal data, we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important for the safeguarding your information.
Please note also that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such events.
Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
In addition, we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis (e.g. a legal obligation) on which we may process it, we may do so on that basis.
Should you like to exercise these rights, please submit a written request with supporting documents, if any, to us at the address listed below:
Contexo Mobility & Tax Consulting Ltd
71-75 Shelton Street
London, WC2H 9JQ
10.7. Communicating with us
When you contact us, whether by telephone, video conference, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.
If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
If a dispute is not settled then, we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
10.9. Retention period
Except as otherwise mentioned in this policy, we keep your personal data only for as long as required by us:
- to provide you with the services you have requested
- to comply with other law, including for the period demanded by the relevant tax authorities
- to support a claim or defence in court
10.10. Compliance with the law
In addition, we fully comply with the following, which govern US tax professionals:
- Circular 230, which contains regulations relating to practice standards
- US Internal Revenue Code § 7216, which is a criminal provision enacted by the US Congress in 1971 that, except as provided in regulations, prohibits tax return preparers from knowingly or recklessly disclosing tax return information or using tax return information for a purpose other than preparing, or assisting in preparing, an income tax return
- US Federal Trade Commission safeguard regulations for data security
The information contained in this website is for general information purposes only, with the understanding that Contexo Mobility and its staff are not engaged in rendering any legal, accounting, or other professional service. As such, it should not be used as a substitute for consulting with professional accounting, tax, legal or other competent advisers. While we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk. In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.
12. Links to Non-Contexo Mobility Websites
13. IT Policy
Every effort is made to keep the website up and running smoothly. However, Contexo Mobility takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.
14. Copyright Notice
This website and its content is copyright of Contexo Mobility & Tax Consulting Ltd – © Contexo Mobility 2014-2023. All rights reserved.
Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
- you may print or download to a local hard disk extracts for your personal and non-commercial use only
- you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material and include the URL of the relevant webpage
You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
Photographs shown on this website are drawn from flickr.com under Creative Commons license permitted for commercial use. Terms of the license can be found on the Creative Commons website.