Privacy Policy

Who we are

tax.com.cy is operated by [Company Name], a company registered in Cyprus (Registration No: [XXXXX]), with registered office at [Address], Nicosia, Cyprus ('we', 'us', 'our', 'the Platform').

tax.com.cy is a technology platform that connects individuals and businesses ('Clients') with independent licensed tax advisors ('Advisors'). The Platform provides software tools, communication infrastructure and case management functionality. Tax advisory services are provided by Advisors, who are independent professionals operating their own regulated businesses through the Platform.

For GDPR purposes, tax.com.cy acts as a data controller in respect of the personal data it collects and processes as part of operating the Platform. Where Advisors access Client data through the Platform to provide their advisory services, the Advisor is a separate data controller in respect of their processing of that data.

What personal data we collect

We collect personal data that you provide directly when using the Platform. This includes identity and contact information such as your full name, email address and telephone number provided when you create an account or contact us.

During the KYC process required by our Advisors, we collect identity verification documents including passport or national identity card copies, date of birth, nationality and residential address. These are collected on behalf of the Advisor conducting the verification.

When you use the Portal, we collect tax-related information including documents you upload, information about your tax filings, income details and financial data that you provide to your Advisor through the Platform.

We collect usage data about how you interact with the Platform, including pages visited, features used and actions taken. This data is used to improve the Platform and is not shared with Advisors or third parties for marketing purposes.

When you use Taxerly AI, your questions are transmitted to Anthropic's Claude API for processing. Anthropic processes this data as a sub-processor under our data processing agreement. Taxerly conversations are not used to train AI models.

When you ask Taxerly a question, it is sent to Anthropic to generate the answer. We log each question with email addresses, phone numbers, bank account numbers and ID numbers masked, use the log to find topics our guides don’t cover yet, and delete each entry automatically after 90 days.

Legal basis for processing

We process your personal data on the following legal bases under UK GDPR and EU GDPR.

Contract performance: we process your identity, contact and account data to operate the Platform and provide the services you have contracted for. This is necessary for the performance of our contract with you.

Legitimate interests: we process usage and analytics data to improve the Platform, prevent fraud and maintain security. We have assessed these interests and determined they do not override your rights and freedoms.

Legal obligation: we may be required to process and retain certain data to comply with applicable law, including Cyprus tax law which requires retention of financial records for six years.

Consent: where we send you marketing communications or newsletters, we do so only with your express consent. You may withdraw this consent at any time.

How we use your data

We use your personal data to provide and operate the Platform, including creating and managing your account, enabling communication between you and your Advisor, storing documents you upload, and providing the Taxerly AI advisory tool.

We use contact information to send you transactional communications about your account and services — including deadline reminders, document notifications and booking confirmations. These communications are necessary for the operation of the service and cannot be opted out of while you maintain an account.

With your consent, we send marketing communications including newsletters, new feature announcements and Cyprus tax updates. You can unsubscribe from these at any time.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

Sharing your data

We share your personal data only in the following circumstances.

With your Advisor: when you engage an Advisor through the Platform, we share the personal data necessary for them to provide their services — including your identity information, tax documents and case correspondence. Your Advisor is an independent data controller and their processing of your data is governed by their own privacy policy.

With service providers: we share data with technology providers who process data on our behalf as data processors. These include our hosting provider (EU-based), Anthropic (for Taxerly AI), and email service providers. All processors are bound by data processing agreements.

Legal requirements: we may disclose personal data where required by applicable law, court order or regulatory authority — including the Cyprus Tax Department, Cyprus Police and other competent authorities.

We do not sell personal data. We do not share personal data with advertisers or marketing third parties.

Data retention

We retain your personal data for as long as necessary for the purposes for which it was collected.

Account data is retained while your account is active and for two years after account closure.

Tax documents and financial records uploaded to the Platform are retained for six years from the relevant tax year, in accordance with Cyprus tax law requirements.

KYC documents are retained for five years from the end of the business relationship, as required by Cyprus AML legislation.

Marketing consent records are retained for the duration of your subscription plus three years.

Where you request deletion of your data, we will delete or anonymise data that we are not legally required to retain.

Your rights under GDPR

Under the EU General Data Protection Regulation (GDPR) and the Cyprus Law providing for the Protection of Natural Persons, you have the following rights in relation to your personal data.

The right of access: you may request a copy of the personal data we hold about you. We will respond within 30 days.

The right to rectification: you may request correction of inaccurate personal data.

The right to erasure: you may request deletion of your data where we no longer have a lawful basis to retain it. Note that we may be required to retain certain data by law.

The right to restriction: you may request that we restrict our processing of your data in certain circumstances.

The right to data portability: you may request a copy of your data in a structured, commonly used and machine-readable format.

The right to object: you may object to our processing based on legitimate interests.

The right to withdraw consent: where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@tax.com.cy. If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection, 1 Iasonos Street, 1082 Nicosia, Cyprus.

International transfers

We process all personal data within the European Union. Our infrastructure is hosted in EU data centres. We do not transfer personal data to countries outside the EU or EEA except where adequate protections are in place.

Anthropic, our sub-processor for the Taxerly AI feature, is a US-based company. Data transmitted to the Anthropic API is processed under Standard Contractual Clauses approved by the European Commission, providing adequate protection for EU personal data.

Contact us

Data controller: [Company Name]
Email: privacy@tax.com.cy
Address: [Address], Nicosia, Cyprus

Data Protection Officer: [DPO Name or 'To be appointed']
Email: dpo@tax.com.cy

Supervisory authority:
Office of the Commissioner for Personal Data Protection
1 Iasonos Street, 1082 Nicosia, Cyprus
commissioner@dataprotection.gov.cy