Air Accounting Limited (AirAccounting) understands that your privacy is important to you and that you care about how your personal data is used. We respect your privacy and your rights to control your personal data (data). We will always protect your data, be clear about the data we collect from you and the reasons why. We do not and will not sell your data to third parties.
- Information About Us
Air Accounting Limited (AirAccounting) is a company registered in England and Wales under company number 10256980.
Registered address: Dudley Court South, The Waterfront, Brierley Hill, West Midlands, DY5 1XN.
Data Protection Officer: Adam Mercy
Email address: firstname.lastname@example.org
Telephone number: 01384 906 007
Postal address: Dudley Court South, The Waterfront, Brierley Hill, DY5 1XN
We are a controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679).
- What Does This Policy Cover?
We will only use your data when the law allows us to. Most commonly, we will use your data in the following circumstances:
- Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to perform the contract for services we are about to enter into or have entered into with you
- Where we need to comply with a legal or regulatory obligation.
This Policy describes:
- What is Personal Data
- Types of data we collect, why and how
- How we use your data
- When we may share or disclose your data
- How to access and control your data
- Communication, marketing and advertising preferences
- How and where we store and process data
- How we secure your data
- Our retention of your data
- Your rights
- Changes to our Policy
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- Types of Data We Collect, Why and How
We will only collect personal data from you that we consider necessary in the context and purpose in which it’s given.
Through your use of our services we may also collect personal data from you about someone else. If you provide us with personal data about someone else, you must ensure that you are authorised to disclose that data to us and that, without us taking any further steps required by applicable data protection laws or privacy laws, we may collect, use and disclose such personal data for the purposes described in the Policy. You must, therefore, take reasonable steps to ensure that the third party concerned is aware of and consents to the various matters detailed in this Policy, including: the fact that their personal data is being collected; the purposes of which that data is being collected; the intended recipients of that data; and the third party’s right to obtain access to the data (including details of how to request access). Where requested to do so, you must assist us with any requests by the third party to access or update the personal data you have collected from them and provided in connection with our Services.
You may be required to provide information when:
- Learning about AirAccounting
- Forming a company
- Purchasing, or enquiring about a service
- Subscribing to an AirAccounting Service
- Using our services
Learning about AirAccounting
In order to gain more information about AirAccounting, you may visit our website, www.airaccounting.com or landing pages, speak to one of our support advisors or request and take out a demo of our accounting software. At these times you may voluntarily provide information about yourself.
We collect: The type of personal data collected may include, full name; phone numbers; email addresses; business type; business name; usage data and statistics; connection data; other unique identifiers such as IP addresses or device ID’s, marketing and advertising responses and preferences.
Why: To make sure you find the information you are looking for and for us to make recommendations to you about our products and services. To follow up your enquiry, provide you with access to business guides, to share news about events and networking opportunities. Additionally, your IP address helps us to understand geographic information about our website users.
How: Data is collected through online forms; surveys; email; chat; telephone, or in person.
Forming a Limited Company
If you require AirAccounting to form a limited company on your behalf you will be asked to provide information relating to yourself, the limited company you want to form and related third parties such as additional directors or shareholders, if you have any. This information is needed so your company can be registered with Companies House.
We collect: The type of personal data collected may include, full name; home/business postal address, phone numbers; email addresses; registered office/service address; date of birth; title; nationality; company details, to include share split, person of significant control; authentication data, for example passport number, national insurance number; place of birth; payment card information; usage data and statistics; connection data; other unique identifiers such as IP addresses or device IDs, marketing and advertising responses and preferences; purchase inquiry and history; products, services or content provided.
Why: To check company name availability and ensure the company is formed correctly with the correct company officers and company information. To comply with legal and regulatory compliance, to include crime prevention. To provide the right guidance, answer your questions and to complete the transaction.
How: Data is collected through online forms; email, chat, telephone or in person.
Purchasing, or Enquiring about an AirAccounting Service
Depending on the type of service you purchase from us you may be asked to share information so we can provide a quote, respond to your enquiry, determine the service best suited for you and to complete the transaction.
We collect: The type of personal data collected may include; full name; home/business postal address; phone numbers; email addresses; payment card information; business type/name/trade; usage data and statistics; connection data; other unique identifiers such as IP addresses or device IDs; marketing and advertising responses and preferences; purchase inquiry and history; products, services or content provided.
Why: To carry out our obligations to provide services you have engaged us to deliver or to perform. To provide a quote, form policy documents, complete the transaction and to follow up your purchase or enquiry. Please note we do not store any card payment data and only use payment information in connection with the purchase made.
How: Data is collected through online forms; email; chat; or telephone.
Subscribing to an AirAccounting Service
If you subscribe to one of our accounting services, you may be asked to provide information relating to you/or your business. The information required will depend on the type of service you are subscribing to. You may also be asked to provide information about third parties, for example, additional employees, directors or shareholders. We may also seek your permission to contact external third parties to gain items such as professional clearance or assignment schedules.
We collect: The type of personal data collected may include, full name; home/business postal address; registered office address; business name/type; phone numbers; email addresses; job title; date of birth; place of birth; title; nationality; marital status; national insurance number; tax codes; HMRC UTR numbers; government issued identification, including passport numbers; sanction and watch list data; details of any other business involvement including shareholding; payment card information; bank account data; usage data and statistics; connection data; other unique identifiers such as IP addresses or device IDs, marketing and advertising responses and preferences; username and passwords for accessing and using our services, purchase inquiry and history; products, services or content provided.
Why: To verify your identity for legal/regulatory compliance and crime prevention. To carry out our obligations to provide services you have engaged us to deliver or to perform. To configure your accounting/payroll software correctly and provide the right support and advice. Analysis for management and marketing purposes.
How: Data is collected through, online forms; surveys; email; chat; telephone, post or in person.
Using our accounting services
During the course of your subscription, you may be asked to provide additional information and to keep us informed of any changes to your circumstances or that of your business. You may also require additional services or products.
We collect: The type of personal data collected may include changes in marital status; changes of home/business postal address; other sources of income; investment activities; changes of your company structure, to include changes to company officers; usage data and statistics; connection data; other unique identifiers such as IP addresses or device IDs, marketing and advertising purposes and preferences; username and passwords for accessing and using our services, purchase inquiry and history; products, services or content provided.
Why: To carry out our obligations to provide services you have engaged us to deliver or to perform. Support you in managing your affairs, provide the right guidance and support at the right time, ensure you continue to be subscribed to the right service for you, to notify you about changes to our services, make suggestions/recommendations to you about other products and services. For related purposes such as updating and enhancing our client records, improving our services, troubleshooting, testing, data analysis, research, profiling, statistical and survey purposes. Analysis for management and marketing purposes and statutory returns, legal and regulatory compliance and crime prevention.
How: Data is collected through, online forms; surveys; emails; chat; telephone; SMS text message; post or in person.
- How Do You Use My Personal Data?
AirAccounting also uses the data we collect to provide you with services and to communicate with you.
AirAccounting uses the data for the following purposes:
- Business Operations
- Communication, Marketing and Advertising
- Providing and enhancing our products and services
- Security, Safety and Dispute Resolution
We use data to run business operations to provide you with the services, profile our user base and develop anonymised aggregate analysis and business intelligence that enables us to operate, protect, make informed decisions and report on the performance of our business.
Communication, Marketing and Advertising
We use data we collect to deliver and personalise our communication with you.
As an example, we may contact you by email or other means of electronic communication to inform you about our services, invite you to take part in a survey, business activities and changes to our services.
If you subscribe to or purchase one of our services, you will also receive service-related communications. These will include system and service support communications, policy, security or software updates.
We use data to ensure we comply with relevant regulation and law. This includes needing to verify your identify if you subscribe to our accounting services. The verification involves:
- a full electoral roll search (your consent is not required for this); and
- credit reference agencies placing a search (soft footprint) on your electronic file and your data being accessed by third parties for the specific purpose of anti-money laundering, credit assessment, ID verification, debt collection, asset reunification, tracing and fraud prevention.
Providing and enhancing our products and services
We use data to provide and improve our services and perform essential business operations. This includes operating our services, maintaining and improving the performance of our products and services, including developing new features, research, testing and providing client support. We may also make aggregated anonymised information publicly available on our website.
Security, Safety, and Dispute Resolution
We use data to protect the security and safety of our products and services and our clients, to detect and prevent fraud, to resolve disputes and enforce our agreements.
Outgoing and incoming telephone calls to our advisory and support teams are recorded for training and monitoring purposes. This process helps us to maintain high standards of service and resolve issues.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
- Do You Share or Disclose My Personal Data?
We do not sell data about our clients and we only share or disclose your data as authorised in this Policy.
We may share or disclose data with the following types of third parties.
Group Companies: AirAccounting may share personal data with other members of our group. This includes AirBooks Limited, as defined in section 1159 of the UK Companies Act 2006.
Legal and Regulatory Bodies: To the extent that we are duty bound by any applicable legal or regulatory requirement to cooperate with any competent legal or governmental authority or agency, we shall do so in accordance with applicable law. This may involve disclosure of your personal data and we will have no legal liability for such disclosures. Please note that, depending on circumstances, AirAccounting may be forbidden from advising you of the fact that your personal data has been disclosed to or requested by such third parties.
Under Section 330 of the Proceeds of Crime 2002 we have a duty to report to the Serious Organised Crime Agency (SOCA) if we know, or have reasonable cause to suspect, that you or anyone connected with your business are or have been involved in money laundering. Failure on our part to make a report where we have knowledge, or reasonable grounds for suspicion, would constitute a criminal offence. We are obliged by law to undertake this reporting to SOCA but are under no obligation to make you aware of this reporting. In fact, we may commit the criminal offence of “tipping off” under Section 333 of the Proceeds of Crime Act 2002 if we were to inform you that a report had been made. In consequence, neither AirAccounting principals nor staff may enter into any correspondence or discussions with you regarding such matters.
Other Parties: With whom it might be necessary to complete a financial or corporate transaction such as a merger or sale of asset.
Suppliers: AirAccounting works with a variety of third party suppliers to perform services such as website hosting, online product/services purchases and email communications. We share your personal data as necessary to complete any transaction or provide a product or service you have requested. These suppliers work on our behalf for the purposes described in this Policy. AirAccounting imposes strict contractual obligations on its suppliers to ensure data is secure, protected and treated in accordance with this Policy and we will take all steps reasonably necessary to maintain compliance with these obligations.
- How Can I Access and Control My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent by email to email@example.com There is not normally any charge for a subject access request. However, if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within less than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required, up to a maximum of 3 months from the date we receive your request. You will be kept fully informed of our progress.
In addition to your rights under the Data Protection Legislation, when you submit personal data, you may be given options to restrict our use of your personal data. In particular we aim to give you strong control on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or by contacting firstname.lastname@example.org
- Communication, Marketing and Advertising Preferences
You can opt out of receiving certain direct communications from AirAccounting.
If you wish to stop receiving promotional or marketing related emails from us, you can do so by following the instructions included in every email sent to you via the unsubscribe link. We respect your choice, and we will stop sending you emails once you unsubscribe or update your preferences. Please note, it may take up to 14 days to process your request.
If you have consented to receive communications or marketing from us by SMS text message, you may stop this by either emailing email@example.com or by advising us over the phone.
If you have become a member, subscribed or purchased any of our services regardless of your preferences, we will continue to communicate with you for service emails, software updates, policy updates, or significant information about our services.
You can adjust the amount of ‘interest-based advertising’ (as described below) you may receive by changing your cookie settings, changing your device settings, and/or opting out of certain advertising networks. If you have opted out of receiving emails from us, we will not use your email for interest-based advertising activities.
Cookies and Other Similar Technologies
Our Site may place and access certain first party Cookies on your computer or device.
By visiting our website or using our services, you agree that you are happy for us to set cookies and similar technologies for the purposes described in this Policy.
We may use some or all of the following types of Cookie:
- Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
- Analytics Cookies
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
- Functionality Cookies
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
- Targeting Cookies
It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests.
- Persistent Cookies
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
- Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for performance, functionality and advertising purposes.
Before Cookies are placed on your computer or device, you will be shown a Cookie pop-up banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies unless those Cookies are strictly necessary; however certain features of Our Site may not function fully or as intended.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
The links below provide instructions on how to control Cookies in all mainstream browsers:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
- Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
- Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge
- Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Safari (iOS): https://support.apple.com/en-gb/HT201265
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
- Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
We sometimes use small graphic images known as ‘pixels’ (also known as web beacons, clear GIFs, or pixel tags). We use pixels in our email, online chat and phone communications (if you have selected to receive such communications) to help us to understand how you interacted with our communication.
Additionally, we also use third party pixels such as those from Google, Facebook, and other advertising networks, to help us provide advertising that is relevant to your interests.
When you use our app, we collect a unique tracking identifier from your device (the Advertising Identifier or “IDFA” on iOS devices and Google Ad ID or “AID” on Android devices) so that we can learn more about users of our app and provide the most relevant messaging and marketing. Although these identifiers are unique to your device, they do not contain any of your data such as name or email address.
How to control Identifier Settings
You can control how these identifiers are used, including the ability to reset them, through your device settings. You can learn about how to control cookie settings on Apple iOS https://support.apple.com/en-gb/HT201265 and Android https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=en, popular device operating systems.
Marketing and Advertising
AirAccounting use several marketing tools in support of our advertising efforts.
To provide this ‘interest-based advertising’, the parties combine non-personal data about your online activities acquired over time which helps cater advertising that we deliver to you.
Examples of this may include an AirAccounting advertisement on a Facebook page, or a Google-owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your data as part of this process.
If you wish to opt out of interest-based advertising email firstname.lastname@example.org.
If you have opted out of receiving communications from us, we will not use your email for interest-based advertising, although you may still be subject to certain interest-based advertising depending upon your browser and device settings.
- Strictly Necessary Cookies
- How and Where Do You Store or Transfer My Personal Data?
By submitting your personal data, you agree to its transfer, storing and processing.
Most personal data is stored electronically on servers or computer systems with controlled access and controlled environments.
AirAccounting servers are located within enterprise-grade hosting facilities that employ robust physical security controls to prevent physical access to the servers they house. These controls include monitoring, 24/7 surveillance and on-site security staff.
Other personal data may be kept in paper form within our office, if needed, although in the main, copies are destroyed after they have been scanned into computer systems.
We will not transfer personal data outside the European Area (EEA) without complying with the provisions of the Data Protection Legislation in respect of such transfer. Where you access our services outside the EEA, it shall be your responsibility to ensure that any access outside of the EEA which results in a transfer of personal data complies with the provisions of the Data Protection Legislation.
If you chose to access your personal data outside of the EEA, you should only do so in a secure environment which means that your browser must support the encryption security used in connection with our services.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.and
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details in Part 1 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
- How we secure your information
AirAccounting is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure.
For example, any personal data transferred to us over the internet is protected with Secure Sockets Layer/Transport Layer Security (SSL/TLS) Encryption Certificate technology. This ensures that all personal data transferred is encrypted to prevent eavesdropping and tampering.
While no service is completely secure, AirAccounting takes precautionary measures and has strict security standards to help prevent data loss, theft, misuse and unauthorised access, disclosure, alteration and destruction or other like incidents that might affect the security of your personal data.
These measures include encryption, password protection, anti-malware, firewalls, server authentication, user profiles, backup/disaster recovery systems, restriction of access to premises and computer systems, as well as use of relevant third-party service providers to provide security.
AirAccounting imposes strict contractual obligations on its suppliers, subcontractors and partners to ensure data is secure, protected and treated in accordance with this Policy and we will take all steps reasonably necessary to maintain compliance with these obligations.
However, we cannot guarantee the security of your personal data while it is being transmitted to us if you do not enter or import it from a secure environment or secure mobile device.
Our services can be accessed through the use of an individual user login and password. To protect the confidentiality of data, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always logout and close your browser when you finish your session, especially if you’re on a public computer. You are ultimately responsible for administering and safeguarding any passwords created to control access. Please note, we will never ask you to disclose your password in an unsolicited email or phone call.
AirAccounting contracts with Openwrks, a data platform, authorised and regulated by the FCA under reference number 709589. We use OpenWrks to enable you to share your financial information with us securely and directly from your bank account so we can understand your income and expenditure without you having to manually upload your bank statements. This service provides an efficient method of transferring receipt and payment details directly from your bank statements to your accounting records and Openwrks security protocols are applied to the transmissions. This service does not give AirAccounting or any third parties the ability to transact via the relevant bank accounts. OpenWrks' terms and conditions can be found here. https://www.openwrks.com/terms-and-conditions
If you have any questions about the security of your data, please contact us at email@example.com.
- How Long Will You Keep My Personal Data?
AirAccounting will not keep your personal data for any longer than is necessary to provide our services or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. As these needs can vary for different data types in the context of different services, actual retention periods can vary significantly.
As an example, the default standard retention period for accounting records is 6 years plus current, otherwise known as 6 years + one. This is defined as 6 years after the last entry in a record followed by first review and/or destruction to be carried out in additional current (+ one) accounting year.
If AirAccounting need to alter, restrict processing of your data, or remove your data, we will inform you.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which AirAccounting will always work to uphold:
- The right to access the personal data we hold about you. Part 7 tells you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 1 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 1 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing; and processing for purposes of scientific/historical research and statistics. In relation to AirAccounting, only the direct marketing ground is applicable. If you wish to object to AirAccounting direct marketing, email firstname.lastname@example.org
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. If you exercise any of your rights and your personal data has been shared with third parties, AirAccounting will notify the third parties that you are exercising your rights as relevant to them.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 1.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 1.
- Changes to our Policy
AirAccounting may modify or update this Policy as and when necessary to reflect feedback and changes in our services. Visiting our website and/or using our services after any modification of this Policy will constitute your acceptance of such modification and updates.
If there are material changes to the Policy or in how Air Accounting uses your personal data, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to regularly review this Policy to learn more about how Air Accounting is using and protecting your data.