Privacy Policy | Money Miles Data Protection

1. Introduction

Welcome to Money Miles Ltd. ("we," "us," or "our"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how Money Miles Ltd. collects, uses, discloses, and protects your information when you use our platform to manually input your earnings and expenses, which we then submit to HM Revenue & Customs (HMRC) for tax purposes. Money Miles Ltd. complies with the General Data Protection Regulation (GDPR) regarding the collection, use, and processing of personal data from individuals within the UK and the European Economic Area (EEA).

2. Information We Collect

Account Information: Full Name, Email Address, Password (securely hashed), Contact Information (optional).
Financial Information: Manually inputted earnings and expenses details (dates, amounts, categories, descriptions), Bank account details (if used for direct integration or payment features), Other financial data relevant to tax calculations.
Tax Identification Information: National Insurance Number (NINO), Unique Taxpayer Reference (UTR), Tax year information, Any other tax-related information requested by HMRC.
Usage Data: Login and logout times, Platform feature usage, IP address, Device information.
Communication Data: Records of communications with our support team.

Money Miles Ltd. collects only the personal data that is necessary for the specified purposes outlined in this policy. We ensure that data is:

Adequate, relevant, and limited to what is necessary (data minimization).
Collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes (purpose limitation).
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation).

3. Lawful Basis for Processing

We use your information for the following purposes, based on the following legal bases:

To provide and maintain the Money Miles Ltd. platform: Contractual Necessity (Article 6(1)(b) GDPR)
To calculate and generate accurate tax reports based on your inputted data: Legal Obligation (Article 6(1)(c) GDPR)
To submit your tax information to HMRC as legally required: Legal Obligation (Article 6(1)(c) GDPR)
To verify your identity and prevent fraudulent activities: Legitimate Interests (Article 6(1)(f) GDPR)
To communicate with you about your account, updates, and support: Contractual Necessity (Article 6(1)(b) GDPR) and Legitimate Interests (Article 6(1)(f) GDPR)
To improve our platform and develop new features: Legitimate Interests (Article 6(1)(f) GDPR)
To comply with legal and regulatory obligations: Legal Obligation (Article 6(1)(c) GDPR)
With your explicit consent: Consent (Article 6(1)(a) GDPR) (Where applicable, e.g., for specific optional features or marketing communications).

4. Sharing Your Information

Money Miles Ltd. may share your information with the following parties:

HMRC: We will share your tax-related information with HMRC to fulfill our legal obligation to submit your tax returns.
Third-Party Service Providers: Money Miles Ltd. engages third-party providers for services such as secure data storage, payment processing (if applicable), and server and platform maintenance. These providers are bound by strict data processing agreements ensuring GDPR compliance.
Legal Requirements: Money Miles Ltd. may disclose your information if required by law, such as in response to a court order or legal process.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to this privacy policy and GDPR requirements.
With your explicit consent: Money Miles Ltd. may share your information with other parties when you give us explicit consent to do so.

5. Data Security

Money Miles Ltd. implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including, but not limited to:

Encryption of personal data at rest and in transit.
Pseudonymization and anonymization of personal data where appropriate.
Measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
Measures to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

6. Data Transfers

Money Miles Ltd. primarily stores and processes personal data within the UK. If, in the future, we transfer personal data to countries outside the UK and the EEA that have not been deemed to provide an adequate level of protection, we will ensure that appropriate safeguards are in place, such as:

Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO).
Other legally recognized mechanisms for ensuring data protection.

7. Data Subject Rights

You have the following rights regarding your personal data held by Money Miles Ltd.:

Right of Access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data.
Right to Rectification: You have the right to obtain from Money Miles Ltd. without undue delay the rectification of inaccurate personal data concerning you.
Right to Erasure ('Right to be Forgotten'): You have the right to obtain from Money Miles Ltd. the erasure of personal data concerning you without undue delay where one of the grounds in Article 17 of the GDPR applies.
Right to Restriction of Processing: You have the right to obtain from Money Miles Ltd. restriction of processing where one of the conditions in Article 18 of the GDPR applies.
Right to Data Portability: You have the right to receive the personal data concerning you, which you have provided to Money Miles Ltd., in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from Money Miles Ltd.
Right to Object: You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you.
Right to Withdraw Consent: If processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Complain: You have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK if you believe that Money Miles Ltd. has not complied with its obligations under the GDPR.

To exercise any of these rights, please contact us using the details provided in Section 12. We will respond to your request without undue delay and within the timeframes required by the GDPR.

8. Data Retention

Money Miles Ltd. retains personal data for as long as necessary to fulfill the purposes for which it was collected, including legal and regulatory requirements. Specifically:

We will retain account data for the duration of your active account and for a period after deactivation as necessary to comply with legal obligations, resolve disputes, or enforce our agreements. This period will typically be 6 years from the end of the tax year.
Tax-related information will be retained for the period required by HMRC regulations, which is currently 6 years from the end of the tax year.
Communication records will be retained as long as necessary to address the inquiry and for a reasonable period thereafter for quality assurance and record-keeping purposes, typically 6 years.
Usage data will be retained for a period necessary for system administration, security, and to improve our services, typically 6 years.
Where data is processed based on consent, we will retain the data until consent is withdrawn.

9. Controller and Data Protection Officer (DPO)

Money Miles Ltd., is the data controller responsible for the processing of your personal data.

10. Automated Decision-Making and Profiling

Money Miles Ltd. does not currently use automated decision-making or profiling that significantly affects individuals. If this changes in the future, we will provide you with information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

11. Changes to This Privacy Policy

Money Miles Ltd. may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on our platform or by email. Your continued use of Money Miles Ltd. after the effective date of any changes constitutes your acceptance of the new Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact Money Miles Ltd. at:
Email: support@moneymiles.co.uk

Last updated: May 2025

Money Miles Ltd. - Privacy Policy