Privacy Policy

Sanctoras Group Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you

Sanctoras Group Limited is registered in England & Wales with company number 12960247 and registered office 124 City Road, London, EC1V 2NX, United Kingdom
Directors: J A Heathcote, R D Thomson-Curtis, C J Heathcote
Sanctoras Private Tax Consultant LLC is registered with the Department of Economy and Tourism in Dubai with company number 12241684 and registered address Office 2058, Dubai Supreme Court Complex, 5 Riyadh Street, Umm Hurair 2, Dubai, United Arab Emirates.
Registered with the Chartered Institute of Taxation for the purposes of Anti-Money Laundering legislation.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, use our services or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Sanctoras Group Limited is the controller and responsible for your personal data.

Contact details

Full name of legal entity: Sanctoras Group Limited.

You can contact us at any time about this privacy policy on hello@sanctoras.com

You have the right to make a complaint at any time to the Information Commissioner’s Office https://ico.org.uk/global/contact-us/ (ICO), the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you . In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for services;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our section on cookies below.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out in the Glossary.
Technical Data from the following parties:
analytics providers such as Google based outside the EU; and
search information providers based inside or outside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to in order to assist you with your pre-contractual interests.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation. e.g. Proceeds of Crime Act 2002 (POCA)
Money Laundering Regulations 2007 (The 2007 Regulations)
The Terrorism Act 2000 (TARP)
Foreign Account Tax Compliance Act (FATCA);
Common Reporting Standards (CRS);
UK Government Beneficial Ownership Register and Persons of Significant Control (PSC) Registers; and
UK Bribery Act.UK Bribery Act.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	To register you as a new customer
Type of data	Identity Contact
Lawful basis for processing including basis of legitimate interest	Performance of a contract with you

Purpose/Activity	To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey
Type of data	Identity Contact Profile Marketing and Communications
Lawful basis for processing including basis of legitimate interest	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity	To enable you to partake in a prize draw, competition or complete a survey
Type of data	Identity Contact Profile Usage Marketing and Communications
Lawful basis for processing including basis of legitimate interest	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data	Identity Contact Technical
Lawful basis for processing including basis of legitimate interest	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

Purpose/Activity	To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data	Identity Contact Profile Usage Marketing and Communications Technical
Lawful basis for processing including basis of legitimate interest	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity	To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data	Technical Usage
Lawful basis for processing including basis of legitimate interest	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity	To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data	Identity Contact Technical Usage Profile
Lawful basis for processing including basis of legitimate interest	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provision.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy below

We receive and store certain types of information whenever you interact with us. Upon your first visit to the Sanctoras website we may send a “cookie” to your computer.

A cookie is a file that identifies you as a unique user. Sanctoras may use cookies to track user trends and patterns to better understand our user base and to improve the quality of our service. Sanctoras may also choose to use cookies to store user preferences.

A cookie can tell us, “This is the same computer that visited the Sanctoras website two days ago,” but it cannot tell us, “This person is John Smith”, or even “This person lives in the United Kingdom.” Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

A number of companies offer utilities designed to help you visit websites anonymously. Although we will not be able to provide you with a personalised experience at Sanctoras if we cannot recognise you, we want you to be aware that these tools exist.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.