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Privacy Policy

1         Introduction

This Privacy Policy (the “Policy”) describes the information we collect from you and how that information is used and shared by us. It applies to personal data that you (or someone on your behalf) provide to us. We may process personal data provided to us for any of the purposes described in this Policy or for other reasons if we tell you them in advance. If you are our client, this Policy should be read in conjunction with the contract you enter into with us (“Engagement Agreement”).

We are committed to respecting the privacy and confidentiality of personal data and complying with data protection legislation. When we process personal data in:

  • the United Kingdom we do so in compliance with the Data Protection Act 2018 and the UK GDPR;
  • the European Economic Area we do so in compliance with the EU GDPR; and
  • Australia we do so in compliance with the Privacy Act 1988.

2         About us

Expat US Tax Service is owned and managed by Andy Milani. See our About Us page.

3         How to contact us

If you wish to discuss any data protection matter please contact the Data Protection Officer:

The Data Protection Officer – Expat US Tax Service, 1452 N Central Ave, Flagler Beach, FL 32136

4         Our role

Our role as a controller or a processor depends upon the nature of our engagement with you. If you are a client this will be defined in our contract with you. But generally:

  • Where we decide the purpose and means of processing, we are a controller;
  • Where we jointly decide the purpose and means of processing with you, we are a joint controller; and
  • Where we process personal data according to your explicit written instructions, in a contract that satisfies Article 28 of the GDPR, we are a processor.

5         How we obtain personal data

Personal data is any information that could identify a living person. We only collect personal data that is necessary and we ask clients to only share personal data that is required. If you provide us with unnecessary personal data, we either return it to you or destroy it if you prefer.

6         The personal data that we process about you:

Full name, company name and job title. Website address, email address and telephone number.  Banking details and tax filing details (if relevant to the service); and any further personal data that you choose to provide in your initial inquiry or during subsequent discussions whether by phone, email or letter.

For clients, we hold employment status and financial details such as salary, other income and investments, tax status and debt level.

Social Security Number, date of birth and other key identified required to prepare and file a US federal and state tax return.

7         Special category personal data

Unless we have a legal basis for doing so we do not collect special category personal data such as health, race or ethnic origin. For certain services or activities, and when required by law or with an individual’s consent this may be necessary.

8         Purpose for the processing and the legal basis for the processing

Processing necessary for the performance of a contract, or steps taken to enter into a contract with our clients, legitimate interests and legal obligation.

9        Retention of personal data

We retain personal data in accordance with legal, regulatory and contractual requirements.

10      Data sharing

We only share personal data with other organizations when we have a lawful basis to do so and when we do so, we put contractual arrangements and security mechanisms in place to protect personal data and to comply with our data protection, confidentiality and security standards.

10.1   Data sharing within the Expat US Tax Service group of companies

Personal data held by us may be transferred to, or disclosed to, other companies in our group of companies. We may do this where necessary for administrative purposes and to provide professional services to our clients. All companies in our group are bound by a Data Sharing Agreement which commits them to share personal data in a secure and lawful manner that respects the rights and freedoms of data subjects.

10.2   Data sharing with other controllers

Depending upon the nature of the service being provided to you we may lawfully share personal data with other organizations. This may change from time to time.

We use specialist organizations to provide certain services, such as data hosting. These organizations (data processors) are bound by a written contract which defines their tasks and responsibilities. We only employ processors that comply with data protection legislation and processors are subject to audit or certification review to ensure continuing compliance. The processors we use may change from time to time.

11      International transfers

We are part of a global association of tax consultants and we sometimes use organizations located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located.

We will not transfer or process personal data outside the country in which a client has contracted, or allow third parties to do so, unless it done in an approved manner in accordance with appropriate levels of security and data protection.

12      Profiling and automated decision-making

We do not perform any profiling based on personal data that has a legal or significant effect upon data subjects. We do not perform any automated decision-making involving personal data.

13      Your right to lodge a complaint with a supervisory authority

If you would like to exercise any of your rights shown above, please contact the Data Protection Officer by post, telephone or by using the email address detailed in section 3.

If you are not satisfied with the response you receive, you have the right to lodge a complaint with the relevant supervisory authority for the territory in which you are contracted.

© 2024 Expat US Tax Service – This Policy is version 20250201 – Published 2 January 2025