Privacy Policy

1. Data Controller Contact Information

The data controller responsible for your information is **Xbot Technology Limited**.

• **Email:** aimtd_enquiry@xbotec.com (Please use the subject "Privacy Request")
• **Address:** [Company House Registered Address], [City], UK

2. Information We Collect

We collect data necessary to provide HMRC-compliant MTD and corporate filing services.

2.1 Personal Identification Data

• Name, email address, phone number.
• Billing information (encrypted and processed by a third-party payment gateway).
• HMRC credentials (stored securely and encrypted to facilitate mandatory digital submissions).

2.2 Financial and Compliance Data (Tax Records)

• All income, expense, and transaction data necessary for MTD ITSA Quarterly Updates (QAs), End of Period Statements (EOPS), and CT600/iXBRL Micro Entity accounts.
• Receipt images and scanned documents uploaded via the mobile app.
• Date of Birth and National Insurance Number (for HMRC identity verification).

3. Legal Basis for Processing

We rely on the following legal bases under GDPR to process your data:

• **Contractual Necessity:** Processing is necessary to provide the MTD filing and bookkeeping services you subscribe to.
• **Legal Obligation:** Processing is required to comply with UK statutory and regulatory obligations (e.g., HMRC MTD requirements, UK company law, anti-money laundering regulations).
• **Legitimate Interests:** Processing for internal research, platform security, and service improvement (e.g., training the AI to improve OCR and error detection, where data is anonymised or aggregated).

4. Your Data Protection Rights

You have the right to:

• **Access:** Request copies of your personal data.
• **Rectification:** Request correction of inaccurate data.
• **Erasure ("Right to be Forgotten"):** Request deletion of your personal data, subject to legal retention obligations (specifically HMRC record-keeping requirements).
• **Restriction/Objection:** Object to or request the restriction of processing.
• **Data Portability:** Request transfer of your data to another service provider.

Note on Erasure:

HMRC requires all businesses and landlords to keep digital tax records for a minimum of 5 years (6 years for LTD companies). We will retain your core tax data for this legally mandated period, even if you close your account.