Tytle Privacy and Data Declaration
1. Introduction
Purpose of this Declaration
We are committed to protecting your privacy and personal data. We comply with all relevant EU legislation, including the General Data Protection Regulation (GDPR), in the collection, use, and storage of personal data.
This declaration informs you about how we treat your personal data when you visit our website, use other digital environments or software connected with our services, and when you use our services in general.
Our Website, Digital Environments, and Simulation Tools
Visiting our website and using other digital environments or software connected with our services include all your visits to tytle.io and its subdomains (the “Website”), and your use of digital environments (such as portals and dashboards) (the “Digital Environments”) created by us to facilitate the collection, use, and storage of your personal data.
Personal Data
Personal data refers to all information relating to you as an identified or identifiable natural person. This includes data that you share with us when visiting our Website, using our Digital Environments, signing up to obtain information, using the tools provided by us to simulate national or international personal tax situations (the “Simulation Tools”), or when you interact with us in other ways.
Minors
Tytle’s website and services are meant to be used by individuals of legal age and not by minors. Our Website, Digital Environments, and services are not aimed at minors.
About Us
Partou Portugal LDA (having the Portuguese fiscal identification number 517161737) operates under the name Tytle. In this declaration, it is referred to as “we,” “our,” “us,” “Tytle,” or “Tytle’s.”
With respect to your personal data, Tytle acts as both a data controller and a data processor depending on the circumstances described below.
Tytle has appointed a data privacy manager who can be contacted regarding questions or concerns about our collection, use, or storage of your personal data. Please use the following contact details:
Name: L.W.P. Pessers Email: dpm@tytle.io
For concerns with the Information Commissioner's Office (ICO), please contact the Comissão Nacional de Proteção de Dados (CNPD) via their website: CNPD
2. About Personal Data and How We Collect, Use, and Store It
Definition
Personal data refers to all information relating to you as an identified or identifiable natural person. When personal data is anonymized in a way that it can no longer be traced back to an individual, it does not qualify as personal data within the meaning of this declaration.
Categories of Personal Data We Collect
- Identity Data: Your name and job title
- Contact Data: Your address, email address, and phone number
- Financial Data: Data regarding your personal finances, including sources of income, claims, assets, and debts, for referrals to partner tax advisors and tax return preparations.
- Marketing and Communication Data: Preferences regarding communications from us and third parties.
- Profile Data: Username, password, data relating to tax simulation, survey input, and other feedback.
- Technical Data: Partial IP addresses, browser type and version, time zone, location, browser plug-ins, operating system, and other technical data.
- Transaction and Payment Data: Referrals to partner tax advisors and payment details.
- Usage Data: Data about how you use our Website and services.
We will not collect, use, or store data belonging to "special categories of personal data" as defined under GDPR.
How We Collect Your Personal Data
We collect personal data in the following ways:
- Directly: When you provide data on our Website, Digital Environments, via emails, phone calls, chat functions, feedback, or signing up for communications.
- Automated: Using cookies, server protocols, or similar technologies when you use our Website, Digital Environments, or Simulation Tools. For further details, refer to our Cookie Statement.
- Third Parties or Public Sources: From analytics providers, advertising networks, payment and banking service providers, or publicly available sources.
How We Use Your Personal Data
We will only use your personal data when legally allowed. Most commonly, we will use your personal data in the following circumstances:
- 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.
- To comply with a legal or regulatory obligation.
Your personal data will not be shared with tax authorities without your consent.
Storing Your Personal Data
We have set out below a description of how we plan to use your personal data and the legal bases we rely on to do so. Our legitimate interests are identified where appropriate.
Marketing
We provide choices regarding the use of your personal data for marketing purposes. You may withdraw consent for direct marketing communications by contacting us.
- Promotional Offers: We may use your data to determine relevant services and offers. You will receive marketing communications if you have requested information, used our services, or registered for promotions and have not opted out.
- Third-Party Marketing: We will obtain your explicit consent before sharing your personal data with third parties for marketing purposes.
- Opting Out: You can opt out of marketing messages at any time by following opt-out links or contacting us. Opting out does not apply to personal data provided as a result of using our services.
Cookies
You can set your browser to refuse cookies or alert you when websites set or access cookies. Disabling cookies may affect website functionality. For details, see our Cookie Statement.
Change of Purpose
We will only use your personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis.
4. Disclosures of Your Personal Data
We may share your personal data with:
- External third parties, including payment processors, analytics providers, and our hosting provider.
- Third parties involved in business transfers. New owners may use your personal data as described in this policy.
We require third parties to respect the security of your personal data and treat it according to the law. They are not allowed to use your personal data for their own purposes and can only process it according to our instructions.
5. International Transfers
Some of our external third parties, including partner tax advisors, are based outside the European Economic Area (EEA). When transferring personal data out of the EEA, we ensure appropriate safeguards, such as:
- Using contracts approved by the European Commission.
- Transferring data to US providers part of the Privacy Shield.
Contact us for information on specific transfer mechanisms.
6. Data Security
We have implemented security measures to prevent accidental loss, unauthorized access, alteration, or disclosure of your personal data. Access is limited to employees, agents, contractors, and third parties with a business need to know. They process data according to our instructions and confidentiality obligations. Procedures are in place to handle suspected data breaches and notify you and regulators as required.
7. Data Retention
We will only retain your personal data as long as necessary for the purposes it was collected, including legal, accounting, or reporting requirements. Retention periods depend on the amount, nature, and sensitivity of the data, potential harm from unauthorized use or disclosure, processing purposes, and legal requirements.
For retention period details, request our retention policy. You can also request data deletion under certain circumstances (see Erasure Request). Anonymized data may be used for research or statistical purposes indefinitely without notice.
8. Your Legal Rights
You have the following rights under data protection laws:
- Access: Request access to your personal data.
- Correction: Request correction of incomplete or inaccurate data.
- Erasure: Request deletion or removal of personal data.
- Objection: Object to data processing based on legitimate interests or for direct marketing.
- Restriction: Request suspension of data processing.
- Transfer: Request transfer of your personal data to you or a third party.
- Withdraw Consent: Withdraw consent for data processing.
To exercise these rights, contact us. No fee is usually required, but we may charge for unfounded, repetitive, or excessive requests.
We may need to request specific information to confirm your identity and ensure your right to access or exercise other rights. We try to respond to legitimate requests within one month, notifying you if it takes longer.