Last updated: 23 May 2018. Thank you for using Capital City Accountancy. We may change this Privacy Policy and will use reasonable endeavours to notify you of these changes. This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of Capital City Accountancy. When this policy mentions ‘Capital City’, ‘we’, ‘us’, or ‘our,’ it refers to the accounting and tax service provided by Capital City Accountancy Ltd, a limited company registered in the UK with company registration number 07445413.

1. Information We Collect

1.1 Information you give to us. We ask for and collect the following personal information about you when you use Capital City. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

  1. Account Information. When you sign up with us, we require certain information such as your first name, last name, address, email address, phone number, nationality, gender, business occupation, and date of birth.
  2. Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
  3. Payment Information. To subscribe to our service we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
  4. Communications with Capital City. When you communicate with Capital City, we collect information about your communication and any information you choose to provide.

1.2 Information you choose to give us. You may choose to provide us with additional personal information in order to obtain a better user experience when using Capital City. This additional information will be processed based on your consent.

  1. Additional Profile Information. You may choose to provide additional information as part of your Capital City profile (such as gender, preferred language(s), marital status, personal avatar image, and personal tax reference information.)
  2. Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Capital City Account, respond to surveys, post to community forums, participate in promotions, or use other features of Capital City.

1.3 Information we automatically collect from your use of the Website. When you use Capital City, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of Capital City.

  1. Geo-location Information. When you use certain features of Capital City, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
  2. Usage Information. We collect information about your interactions with Capital City such as the pages or content you view, and other actions on Capital City.
  3. Log Data and Device Information. We automatically collect log data and device information when you access and use Capital City, even if you have not created a Capital City account or logged in. That information includes, among other things: details about how you’ve used Capital City (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and cookie data.
  4. Cookies and Similar Technologies. We use cookies to store and collect information about your usage of the Website in order to enhance your online experience and to help us improve the quality of our services.

1.4 Information we collect from Third Parties. Capital City may collect information, including personal information, that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  1. Third Party Services. If you link, connect, or login to Capital City with a third-party service (e.g. Google, Facebook, LinkedIn), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  2. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks.

2. How we use Information we Collect

2.1 We use, store, and process information, including personal information, about you to provide, understand, improve, and develop Capital City, create and maintain a trusted and safer environment and comply with our legal obligations.

2.2 We intend to process personal data for the following purposes:

  1. To enable us to supply professional services to you as our client.
  2. To fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).
  3. To comply with professional obligations to which we are subject as a member of AAT.
  4. To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.
  5. To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
  6. To contact you about other services we provide which may be of interest to you if you have consented to us doing so.

2.3 Provide, Improve, and Develop Capital City: We use, store, and process information to:

  1. Enable you to access and use Capital City.
  2. Operate, protect, improve, and optimize Capital City and the User experience, such as by performing analytics and conducting research.
  3. Provide customer service, and technical support.
  4. Send you service or support messages, updates, security alerts, and account notifications.
  5. If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any purpose you authorize at the time of collection.

We process this information given our legitimate interest in improving Capital City and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2.4 Provide, Personalize, Measure, and Improve our Advertising and Marketing: We use, store, and process information to:

  1. Enable you to access and use Capital City.
  2. Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Capital City or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
  3. Personalize, measure, and improve our advertising.
  4. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Capital City or its third party partners.
  5. Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Website, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

Your explicit consent is required for processing your personal information for the purposes listed in this section. Once consent is granted, you can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Capital City Account.

2.5 Our legal basis for the intended processing of personal data. Our intended processing of personal data has the following legal bases:

  1. At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above in Section 2.2.
  2. The processing is necessary for the performance of our contract with you
  3. The processing is necessary for compliance with legal obligations to which we are subject (e.g. MLR 2017).

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.

3. Sharing and Disclosure

3.1 With your Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third-party application or website to access your Capital City Account, or when you add a new User to your Capital City Account, or when you participate in promotional activities conducted by Capital City partners or third parties. Capital City has no control over, and takes no responsibility for, the privacy practices or content of these applications/Users. You are responsible for checking the privacy policy of any such applications so that you can be informed of how they will handle personal information.

3.2 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. Capital City may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Capital City, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Capital City, its employees, its Members, or members of the public.

3.3 Business Transfers. If Capital City undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.4 Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. Third Party Partners and Integrations

4.1 The Website may contain links to third party websites or services, such as third-party integrations, co-branded services, or third party-branded services (Third Party Partners). Capital City doesn’t own or control these Third-Party Partners and when you interact with them, you may be providing information directly to the Third-Party Partner, Capital City, or both. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

5. Your rights

5.1 Your rights. You may exercise any of the rights described in this section before your Capital City Data Controller by sending an email to Please note that we may ask you to verify your identity before taking further action on your request.

5.2 Managing Your Information. You may access and update some of your information through your Account settings. If you have chosen to connect your Capital City Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

5.3 Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Capital City Account).

5.4 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.5 Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide our Service to you, you can request that we erase your personal information and close your Capital City Account. Please note that if you request the erasure of your personal information:

  1. We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Capital City Account for fraud or safety reasons, we may retain certain information from that Capital City Account to prevent that Member from opening a new Capital City Account in the future.
  2. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Capital City may keep some of your information for tax, legal reporting and auditing obligations.
  3. Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  4. Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

5.6 Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your personal information by Capital City you may withdraw your consent at any time by changing your Account settings or by sending a communication to Capital City specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Capital City override your own.

5.7 Objection to Processing. In some jurisdictions, applicable law may entitle you to require Capital City not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Capital City will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time ask Capital City to cease processing your data for these direct marketing purposes by sending an e-mail to

5.8 Automated decision-making. We do not intend to use automated decision-making in relation to your personal data.

5.9 Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by Capital City before the competent data protection authorities.

6. Retention of personal data

6.1 When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all our records relating to you as follows:

  1. where tax returns have been prepared it is our policy to retain information for 7 years from the end of the tax year to which the information relates.
  2. where ad hoc advisory work has been undertaken it is our policy to retain information for 3 years from the date the business relationship ceased.
  3. where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 7 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.

6.2 Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter. Prior to the destruction of documents best efforts will be made to contact you to arrange the secure transfer of documents to you.

6.3 You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:

Individuals, trustees and partnerships

  1. with trading or rental income: five years and 10 months after the end of the tax year;
  2. otherwise: 22 months after the end of the tax year.

Companies, LLPs and other corporate entities

  1. six years from the end of the accounting period.

6.4 Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract.

7. Security

7.1 We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Capital City Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Capital City Account, please contact us following the instructions in the Contact Us section of the Website.

7.2 Transfers of personal data outside the EEA. Your personal data will be processed in the EEA only.

8. Changes to this Privacy Policy

8.1 Capital City reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the Last Updated date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Website will be subject to the revised Privacy Policy.

9. Contact us

9.1 If you have any questions or complaints about this Privacy Policy or our information handling practices, you may contact us following the instructions in the Contact Us section of the Website.