1. PURPOSE OF THIS POLICY
This policy describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) in the EU
Please read the following carefully to understand our practices regarding personal data and how we will treat it.
2. ABOUT US
Harris Horoviz Consulting & Tax Ltd and Leon Harris & Co (“H2CAT”) are based in Israel and engaged in routine accounting and tax reporting, tax and business consulting. The owners, Leon Harris and Eyal Horoviz are Israeli Certified Public Accountants, Leon Harris is also a UK Chartered Accountant.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- You request a proposal from us in respect of the services we provide.
- You engage us to provide our services and also during the provision of those services.
- You contact us by email, telephone, post or social media.
- From third parties and/or publicly available resources.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- Your personal details such as your name and/or address.
- Details of contact we have had with you in relation to the provision, or the proposed provision, of our services.
- Details of any services you have received from us.
- Our correspondence and communications with you.
- Information about any comments and inquiries you make to us.
- Information from research, surveys, and marketing activities.
- Information we receive from any other sources.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our agreement with our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- Carry out our obligations arising from any agreements entered into between our clients and us (which will usually be for the provision of our services):
- Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented or not objected to be contacted for such purposes;
- Seek your thoughts and opinions on the services we provide, and
- Notify you about any changes to our services.
In some circumstances we may anonymize or pseudonymize the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our statutory or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data for the agreed purpose(s).
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers include mainly: IT services, professional advisory services, administration services, marketing services and banking services.
Our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. OUR POLICY AS WE ARE OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We are based in Israel which is outside the EEA. Nevertheless, we shall endeavor to uphold GDPR principles
We will not disclose information without your consent, unless compelled to by relevant tax and other laws or to meet the professional obligation you require from us. Our policy is to retain such information long enough to meet the relevant statute of limitations (4 – 10 years in Israel, sometimes longer) and to answer any questions which may arise
Should you require further information about these measures, please contact us.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will endeavor notify you and any applicable regulator of a suspected breach where required.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, under the GDPR you may:
- Request a copy of your personal data held by us. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
- Please note that all this is subject to tax requirements to maintain adequate accounting and tax records and retain them for prescribed periods of time.
If you want to exercise any of the above rights, please email our data point of contact (see below).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
1. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw any prior consent, please email our data protection point of contact.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- CHANGES TO THIS POLICY
2. CONTACT US
If you have any questions regarding this policy or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection points of contact are Leon Harris ([email protected]) or Eyal Horoviz ([email protected]).
As always, consult experienced tax advisors in each country at an early stage in specific cases.