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Privacy Policy

Last Updated: August 16, 2024

Introduction

At Minefield Navigator, we are committed to protecting the privacy and security of our customers' data. This Privacy Policy explains how we collect, use, process, store, and protect the information provided by users of our VAT filing management application, Minefield Navigator. We never sell customer data.

Minefield Navigator is operated by Simply Apply Limited, Delaware corporation, 304 South Jones Boulevard, #8701 Las Vegas, NV 89107, USA, which is the controller of your data.

This Privacy Policy applies to users worldwide, with specific provisions tailored to comply with the privacy laws of the European Union, the United Kingdom, and the United States. In cases where different privacy laws may apply to the same data, we will prioritize the most protective standards to ensure your data is handled in accordance with the highest levels of privacy protection. If data is transferred between different jurisdictions as necessary for the service quality, there are safeguards in place, such as standard contractual clauses, to comply with the requirements of GDPR and similiard regulation.

Information We Collect

  • Company Details: This includes email, company name, company address, VAT numbers, registration numbers, names of company directors (in case of legal persons), bank account information (IBAN, BIC/SWIFT, bank name and currency of UK and EU bank accounts) and any other business information necessary to file VAT returns in the UK or any EU jurisdiction.
  • Tax Documents: We collect tax documents necessary to calculate VAT and file VAT returns, including VAT transactions on Amazon, invoices, and customs documents and forms.
  • For VAT registration purposes, we may collect any documents necessary as per national legislation, including company formation documents such as Articles of Association, Memorandum of Association, and Certificate of Incorporation, or data on the company's representative, such as the passport.
  • For AML compliance, we may collect additional data required by law so that the attorney as our business partner can establish the risk level and identity of the client and in some cases provide the necessary checks as required by AML legislation.
  • We use cookies and similar tracking technologies to enhance your experience on our website and application. These may include:
    • Essential Cookies: Necessary for the operation of our application.
    • Analytics Cookies: Used to collect information on how users interact with our application, helping us to improve its functionality. Explicit consent for non-essential cookies is required.
  • Cookies are small text files stored on your device when you visit our website or use our application. These files contain data that help us recognize your device, remember your preferences, and improve your user experience. Cookies also allow us to analyze how you interact with our services, so we can enhance our offerings and deliver content that is relevant to you. You can manage your cookie preferences at any time through your browser settings or our Cookie Management Tool.
  • We collect the information from the web applications, text messages, e-mails, phone calls, post, or similiard standard means of communication.

Purpose of Data Processing

  • VAT Registration: To register for VAT in any given country as requested and in the future.
  • Generating VAT Returns: To accurately calculate and generate VAT returns and related documents, such as EC sales lists.
  • Record Keeping: To maintain records accessible for review and compliance with VAT legislation in the UK and the EU, and with the AML legislation.
  • Record Sharing: We may share your data with third-party service providers who assist us in delivering our services. These third parties are bound by contractual obligations to protect your data and use it only for the purposes specified by us. The categories of third parties we may share data with include: legal service providers (attorneys and tax advisors), cloud service providers, payment gateways, bank, e-mail processing and similar. We carefully select third-party service providers to ensure they meet our high standards for data protection. Each third-party provider is subject to a data processing agreement that mandates compliance with applicable privacy laws and requires the implementation of appropriate security measures. We regularly review and monitor these providers to ensure ongoing compliance.
  • Service Improvement: To enhance the functionality and user experience of our application.
  • Filing VAT returns in the UK through our free HMRC recognized VAT application.
  • We only collect information strictly necessary for our software to work and for legal compliance. 

Legal basis for processing information

In addition to consent, we may process your data under the following lawful bases:

  • Contractual Necessity: Processing your data is necessary to perform the services you have requested (the provision of Documents, and the sharing with the attorneys in the EU countries if your purchased services requires it and you authorize it). Our business partners (attorneys) are required by law to protect confidentiality and provide the services with strict respect to privacy.
  • Legal Obligation: We are required to process certain data to comply with our legal obligations, such as the AML legislation. We also provide the service of storing data for the contracted attorneys who are required by law to have documentation of their legal service and AML obligations.
  • Legitimate Interests: We may process your data for our legitimate interests, such as improving our services, provided that these interests do not override your rights and freedoms.

When processing your data under the basis of legitimate interests, we conduct a thorough assessment to ensure that our processing does not disproportionately impact your privacy rights and freedoms. This includes considering the necessity of the processing and implementing safeguards to minimize any potential impact on you.

Data Security

We are responsible for protecting your data. We take the security of your data seriously and comply with relevant EU (GDPR) and UK laws (UK GDPR). Our data storage and processing practices are designed to ensure the confidentiality, integrity, and availability of your information. We implement industry-standard security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal and business information. We encrypt access tokens and personally identifiable data when it is stored and in transit.

Security Risk Notifications and Security Breach Procedures

Customers or third parties can tell us you about a security risk or incident at the following email address: support@minefieldnavigator.com. We will investigate and take action to fix any security risk or incident without delay. 

In case of a security breach, we will notify you if you are affected as well as relevant national authorities in accordance with relevant national laws, including GDPR laws in the European Union and the relevant state authorities as required by U.S. state laws, within the timelines and using the methods prescribed by each applicable law. In the UK, we will notify ICO within 72 hours of becoming aware of a breach in accordance with the requirements set forth by the UK GDPR. For users who have given their authorization to use our free HMRC recognized app to submit their UK VAT returns, we will also notify HMRC.

Data Retention

We retain the collected information for as long as necessary to provide our services and as required by law.

  • Transactional Data: Retained for a minimum of 6 years to comply with tax and accounting regulations.
  • AML data: AML regulations generally require that records be kept for at least 5 years after the business relationship has ended or after the date of the transaction.
  • Product safety data: Retained for 10 years from the entry of the product to the market as required by GPSR.
  • User Account Data: Retained for the duration of your account and up to 1 year after account closure, unless otherwise required by law or requested by you.

Upon your request to cancel the subscription and transfer your data to a new attorney, we will promptly hand over all relevant documents and information collected during the course of representation. We may retain copies of such data for a period of up to 6 years, primarily for tax purposes and to defend against any potential claims. 

Your Rights

  • You have certain rights regarding your personal data, including the right to access, correct, delete, or transfer your data, as well as the right to withdraw consent for its processing, unless the storage is required by law.
  • You can request that we restrict the processing of your personal data under certain circumstances.
  • You have the right to receive your personal data in a structured, commonly used, and machine-readable format (where available), and to transmit that data to another controller.

For residents of California, you have additional rights under the CCPA, including:

  • Right to Know: You have the right to request information about the categories and specific pieces of personal data we have collected, used, disclosed.
  • Right to Delete: You have the right to request the deletion of your personal data, subject to certain exceptions, such as when we need to retain data to comply with legal obligations, resolve disputes, or enforce our agreements. If an exception applies, we will inform you of the specific reason why your data cannot be deleted.

Please contact us by email at support@minefieldnavigator.com if you wish to exercise any of these rights. 

Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or legal requirements. We encourage users to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions or concerns about this policy or our data processing practices, please contact us at support@minefieldnavigator.com.

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