Privacy Policy - Global Mobility Tax Services

Effective Date / last updated: 16 November 2019

By visiting, browsing or utilizing this Global Mobility Tax Services website, you acknowledge that you have read, understand and are accepting the practices described in this Privacy Notice. Please read this policy carefully.

This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

Global Mobility Tax Services (GMTS) (in this Privacy Notice, “us”, “we” and “our”) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679.

What Personal Information About Customers Does Global Mobility Tax Services Gather?

The information we learn from customers helps us personalize and continually improve our services and your user experience at Global Mobility Tax Services. Here are the types of information we gather.

Information You Give Us: We receive and store any information you enter on our website or give us in any other way. You provide most such information when you order, use our web products, or communicate with customer service. For example, you provide information when you communicate with us face to face, by phone, e-mail, or otherwise; sign up to our newsletter; through intermediaries; when you complete (or we complete on your behalf) client on-boarding or application or other forms; from publicly available sources or from third parties, most commonly where we need to conduct background checks about you. As a result of those actions, you might supply us with such information as your name, address, phone numbers, date of birth, tax identification number, passport number, national identity card details, country of domicile and/or your nationality. You may also supply us information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, your bank account details, your goals and objectives in procuring our services, your employment, education, family or personal circumstances, and interests, where relevant to assess whether you may represent a politically exposed person or money laundering risk. You can choose not to provide certain information, but then you might not be able to take full advantage of many of our features and services. We use the information that you provide for such purposes as responding to your requests, customizing services for you, improving our services, and communicating with you.

Automatic Information: We receive and store certain types of information whenever you interact with us. Examples of the information we collect and analyze include the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information such as browser type and version, operating system, and platform; the full Uniform Resource Locator (URL) clickstream to, through, and from our website, including date and time; cookie number; and products you viewed. During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Like many websites, we use “cookies,” and we obtain certain types of information when your web browser accesses a Global Mobility Tax Services website. All cookies used by our website are secured by SSL encryption. A number of companies offer utilities designed to help you visit websites anonymously. Although we will not be able to provide you with a personalized experience at Global Mobility Tax Services if we cannot recognize you, we want you to be aware that these tools exist.

Does Global Mobility Tax Services Share the Information It Receives?

Information about our customers is an important part of our business, and we are not in the business of selling it to others. We share customer information only as described below and with affiliated entities that either are subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.
Global Mobility Tax Services may engage third-party service providers (for example lawyers, accountants, IT / data storage companies or public relations advisers) to assist us in providing our services to customers. These third-party providers may provide technical, legal or other professional services. These third parties will not access, process, or store personal data in the course of providing their services unless authorised to do so by you (for example via the Engagement Letter signed with us) in order to deliver the requested services from us.
Global Mobility Tax Services maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our obligations.

Affiliated Businesses We Do Not Control:

Agents: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, and providing customer service. These agents have access only to personal information needed to perform their functions, but may not use it for other purposes.
Business Transfers: As we continue to develop our business, we might sell or buy business assets, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise). Also, in the unlikely event that Global Mobility Tax Services., or substantially all of its assets are sold, customer information will of course be one of the transferred assets.
Protection of Global Mobility Tax Services and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Global Mobility Tax Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. However, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Notice.
With Your Consent: Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

How Do You Use The Information You Hold About Me?

We use your personal data for the following:

To prepare a proposal for you regarding the services we offer;
To provide you with the services as set out in our Engagement Letter with you or as otherwise agreed with you from time to time;
To deal with any complaints or feedback you may have;
For any other purpose for which you provide us with your personal data.
We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we may use your personal data for the following:

For marketing to you (please see the separate section on Marketing below);
Training our staff or monitoring their performance;
For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
Seeking advice on our rights and obligations, such as where we require our own legal advice;

Under such circumstances we will share your personal data with our advisers or agents where it is necessary for us to obtain their advice or assistance.

Marketing

We will send you marketing communications about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.

If you object to receiving marketing communications from us at any time, please contact us using the details provided in the section on Enforcement below.

How Secure Is The Information You Hold About Me?

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
Access to any system which contains your information is restricted by password protection at both application and filesystem levels.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

Which Information Can You Make Accessible For Me?

Global Mobility Tax Services gives you access to information about your account and your interactions with us for the limited purpose of viewing and, in certain cases, updating that information.

Compliance

Choice

Global Mobility Tax Services offers individuals the opportunity to choose (opt out) whether their personal information is to be disclosed to a third party or to be used for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by the individuals.

Any use of personal data for new purposes that have not been listed in the Privacy Policy will required Global Mobility Tax Services to obtain explicit consent from the EU citizen or individual whose data has been collected to determine if it is appropriate to use their data in that fashion that may involve disclosure of said information to a third party.

Access

EU citizens and/or individuals whose data Global Mobility Tax Services collects have the right to access personal information about them that Global Mobility Tax Services holds and to be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of EU General Data Protection Regulation 2016/679 , except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. Requests for access, correction, amendment, or deletion should be sent to: [email protected].

To find out more about your rights please refer to the EU regulator in the place where you are located (in the EU).

Data Integrity and Purpose Limitation

Global Mobility Tax Services collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. Global Mobility Tax Services does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. Global Mobility Tax Services takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.

Enforcement

Global Mobility Tax Services commits to resolve complaints about our collection or use of your personal information. For any inquiries or complaints regarding our Privacy Policy individuals should first contact Global Mobility Tax Services at:

Global Mobility Tax Services (GMTS)
Subject: Privacy
e-mail: [email protected]

We will investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Notice.

Global Mobility Tax Services has further committed to refer unresolved Privacy Policy complaints to the European DPA, an alternative dispute resolution provider located in the EU. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en for more information or to file a complaint. The services of the European DPA are provided at no cost to you.

Global Mobility Tax Services commits to cooperate with the EU data protection authorities (DPAs) and the UK Information Commission Officer and comply with the advice given by the panel and Commissioner with regard to client data transferred from the EU and the UK as part of the business relationship.

Global Mobility Tax Services has a requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Changes to the Privacy Policy

Global Mobility Tax Services may update this Policy at any time by publishing an updated version here.