Privacy Policy

Here at Winchurch Services, we respect your privacy and are committed to protecting your personal data. This document 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, particularly in relation to the UK general data protection regulation (UK GDPR) and the Data Protection Act 2018.



This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when submitting an online application for a tax refund.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.


Winchurch is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “Our” in this Privacy Policy).


If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us:

Email address: [email protected].

Users have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK 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.

ICO Contact Details:

Information Commissioner’s Office
Wycliffe House
Water Lane
Cheshire SK95AF
Helpline number: 03031231113
ICO website:


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.


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


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, whether internally or on approved third party storage platforms, which we have grouped together as follows:

  • Identity Data includes first name, last name, Title, claim number or similar identifier. For more details about data provided to third parties, please refer to article 5 of this Privacy Policy.
  • Identifty Verification includes Date of Birth, National Insurance number, Nationality, Place of birth, Sex, Passport number, Driver’s licence number, Photo, spouse.
  • Contact Data includes Postal Address, Tel Number name, email address and telephone number.
  • 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.
  • Usage Data includes information about how you use our platform 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


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 with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.


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:
    • fill in an online application on our website
    • subscribe to our service.
    • request marketing to be sent to you; or
    • give us feedback or contact us through any means (email, Facebook messenger, phone, etc).
  • Automated technologies or interactions. As you interact with our website, we will 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.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    1. analytics providers such as Google based outside the EU (which helps us track the analytics of visitors to our site), and Facebook pixel (which may collect data about you from our website to help us track conversions from Facebook adverts, optimize our adverts and build targeted audiences);
    2. advertising networks.
    3. search information providers
    4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal.
    5. Identity and Contact Data from publicly available sources.
    6. Identity Contact and Financial Data from HMRC (as set out in the Digital Tax section).
    7. Identity and Contact data from social media platforms such as Facebook


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:

  • Generally, we will use Contract as the legal Basis for Processing Personal data. This is in relation to performance of the contract we are about to enter into, or have entered into with you, i.e. the processing of your online application.
  • Sometimes where it is necessary, we rely on legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation to comply with Money Laundering requirements
  • Generally, we do not rely on consent as a legal basis for processing your personal data although we will require you to opt-in to gain your consent before 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.


We have set out below, in a table format, legal bases we rely on to Process your data.

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.

Type of Data Purpose Legal Basis for Processing
Necessary Cookies Website Operation Legitimate Interest
Technical, Analytical and Preference Cookies Website Operation Consent
Contact Data Contracting, Onboarding, Verifying client and Performing Tax Services Contract
Identity Data Contracting, Onboarding, Verifying client and Performing Tax Services Contract
Identity Verification Data Contracting, Onboarding, Verifying client and Performing Tax Services Contract
Financial Data Performing Tax Services Contract
Tax Data Performing Tax Services Contract
Employment Data Performing Tax Services Contract


We will process your personal data to:

  • Use analytics to improve our services and website.
  • Process your application for reclaiming overpayment of tax
  • Request a service review.
  • Process payments and fees
  • Notification of changes to our Policies (Terms and conditions and privacy policy)
  • Comply with legislation, regulatory bodies and law enforcement.
  • Retain records of your file for defense and exercise of legal claims.


Through its ‘Making Tax digital programme, HMRC has digitised some tax records. One of service HMRC has created is the Personal Tax Account, to help you manage your tax details online.

A Personal Tax Account (PTA) is an HMRC service that allows individuals to view and manage their tax details online. We will invite you to connect your PTA to our HMRC agent account, enabling us to view some of your digital tax records. Our retention periods are detailed in our retention policy for the information we collect during this process.
We are required by HMRC to conduct certain checks to assess the merits of your claim before we submit claims to them. The most effective way for us to complete these checks is to connect your PTA to our agent account. Once connected, we will use the information within your PTA to determine whether to your claim is valid. We will also use this access annually to review your tax details and contact you to let you know the outcome of this review.

You can remove our access to your PTA at any time by emailing us at [email protected] or by logging in to your PTA and removing our access directly.

An HMRC agent account is an HMRC service that allows an agent, like us, to view customers’ tax details if authorised to do so. You can authorise us to view some of your tax details through your PTA as set out above. Alternatively, you can authorise us to view some details by signing a Tax Agent Authority (64-8).


We may send you service messages related to a Claim. Service messages may include invoices and reminders. You may receive services messages regardless of whether you are opted into marketing or not.


We depend on on explicit opt-in consent for marketing, in compliance with both the PECR (Privacy and Electronic Communications (EC Directive) Regulations 2003) and the Data Protection Act 2018. If you consent to receiving marketing from us, we may contact you about additional services.

If you wish to change your marketing preference after opting-in, you may at any time by utilising the links in marketing communication or contacting us at [email protected].

We utilise pixels to identify social media traffic. Pixels allow us to know if you have visited our website, and which pages. We use this information to improve our marketing. We market our services on Facebook, and independent websites. To opt-out from the pixel on those platforms you will need to go through the marketing preferences sections on those platforms.


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 made a review with us and you have not opted out of receiving that marketing.


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


You can ask us or third parties to stop sending you marketing messages at any time.


Please refer to our Cookies Policy for details about how we use cookies.


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.


We may share your personal data with third parties purto whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


Some of our third parties, employees & contractors are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK, To countries:

  • which the UK Regulator’s (ICO) Office has verified have adequate data laws to protect your personal data there as it would be protected in the UK; or
  • in countries the UK Regulator (ICO) has not verified have adequate data laws to protect your personal data there as it would be protected in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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, necessary to provide our service to the customer. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. Please see our Data Retention policy for more information.


Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.


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 is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.



  • Service providers acting as processors such as marketing services providers, IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Tax regulators and other authorities acting as processors or joint controllers.


You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


Please note that the terms of this Privacy Policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction for any disputes.

© Winchurch Services 2024, all rights reserved.
Winchurch Services is incorporated under the Companies Act 2006 № 12349393 ICO № ZA715789