Privacy Policy

1. Introduction

Countex Finance Ltd ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy informs you as to how we look after your personal data when you visit our website (https://countex.io/) (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

Countex Finance Ltd is a company registered in England and Wales under company number 12720370. Our registered office is located at Future Space, UWE North Gate, Filton Road, Bristol, BS34 8RB.

2. The Data We Collect About You (including during onboarding)

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 as follows:

• Identity Data: includes first name, last name, username or similar identifier, title, date of birth, and copies of identity documents where required for compliance purposes.
• Contact Data: includes billing address, delivery address, email address, and telephone numbers.
• Financial Data: includes bank account details, tax identifiers (including National Insurance number and UTR where applicable), financial records, invoices/receipts, payroll information, and other finance information necessary for the provision of outsourced CFO, accounting, and tax services.
• Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
• Due Diligence / AML Data: includes information required to verify identity and address, beneficial ownership and control information, and screening/verification results (e.g., sanctions/PEP checks) where required by anti-money laundering laws.
• Client Business Data: includes information you or your organisation provide to us in the course of onboarding and service delivery (for example, company details, accounting records, VAT records, management accounts, statutory accounts information, and communications). This may include personal data relating to your employees, contractors, suppliers, customers, directors, shareholders, and other stakeholders.
• 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 website and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. How Your Personal Data Is Collected

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

• Direct interactions: You may give us your Identity, Contact, Financial, Due Diligence / AML, and Client Business Data by filling in forms (including via our website) or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you enquire about our services, request a proposal, start onboarding, subscribe to our publications, or request marketing to be sent to you.
• 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.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources including Companies House, HMRC, and providers of financial software (e.g., Xero, Dext, or similar platforms).

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 perform the contract we are about to enter into or have entered into with you.
• 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 (such as ICAEW regulations, anti-money laundering legislation, and tax laws).

5. Purposes for Which We Will Use Your Personal Data

We use your data for the following purposes:

• To respond to enquiries and assess whether we can provide services to you.
• To register you as a new client and complete onboarding (including identity verification and anti-money laundering checks).
• To provide outsourced CFO, accounting, and tax services (including bookkeeping, VAT, payroll support, management accounts, statutory accounts, corporation tax and personal tax support where applicable, and general financial reporting and advisory).
• To process and deliver your service including managing payments, fees, and charges.
• To comply with legal and regulatory obligations, including reporting and filings with HM Revenue & Customs, Companies House, and compliance with anti-money laundering regulations.
• To manage our relationship with you (e.g., notifying you about changes to our terms).
• To administer and protect our business and this website.
• To use data analytics to improve our website, services, marketing, and client relationships.

6. Data Processor Role

In many instances, Countex Finance Ltd acts as a Data Processor on behalf of our clients (the Data Controllers) when we handle client business data as part of delivering outsourced CFO, accounting, and tax services. This may include personal data relating to your employees, contractors, suppliers, customers, directors, shareholders, and other stakeholders.

In such cases, we will:

• process personal data only on your documented instructions (including as set out in our engagement letter / services agreement);
• take appropriate technical and organisational security measures to protect that data;
• ensure that persons authorised to process the data are bound by confidentiality obligations; and
• assist you, where applicable and proportionate, with meeting your obligations under data protection law (for example, handling data subject rights requests).

Where we determine the purposes and means of processing for our own business purposes (for example, managing our own client relationship, billing, and compliance records), we act as a Data Controller for that processing.

7. Disclosures of Your Personal Data

We may share your personal data with the parties set out below:

• HM Revenue & Customs (HMRC), Companies House, regulators, and other authorities based in the United Kingdom who require reporting, filings, or access to information in certain circumstances.
• Anti-money laundering (AML) and identity verification providers (including screening providers) where required to meet our legal obligations.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Service providers acting as processors who provide IT and system administration services (e.g., cloud accounting software).
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

8. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data (including sensitive financial 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 and who are subject to confidentiality obligations.

We also maintain procedures to deal with any suspected personal data breach and will notify you and/or any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law, we have to keep basic information about our clients (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being clients for tax and regulatory purposes.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including 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 (data portability).
• Right to withdraw consent at any time (where we rely on consent).
• Right to complain to the Information Commissioner's Office (ICO) (www.ico.org.uk).

If you wish to exercise any of the rights set out above, please contact us at support@countex.io.

11. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

• Full name of legal entity: Countex Finance Ltd
• Email address: support@countex.io
• Postal address: Future Space, UWE North Gate, Filton Road, Bristol, BS34 8RB
• Telephone number: 01174 501 908