We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Direct Marketing & Opting Out
We have contacted you using direct marketing channels (post) to offer our services.
If you do not wish to receive our direct marketing letters, you are free to opt out by post using our reply paid envelope, or by email to ovintcent@vintcentandco.com or telephone us on 01242 232 288.
PRIVACY POLICY
Vintcent & Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when we contact you and tell you about your privacy rights and how the law protects you.
How is your personal data collected
We use different methods to collect personal data including through:
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Publicly available sources (Companies House) – Where details of a standalone investment in individual companies is made public as a matter of law, or where you have consented to share information.
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Direct interactions. You may give us your contact and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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Enquire about our services
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Instruct us to act on your behalf
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Complete forms we have provided
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Otherwise contact us eg with a query, or a complaint
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Give us some feedback
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Visit our website
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We may also collect your personal data when a third party to whom you have given permission (eg HMRC) shares with us information they hold about you.
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:
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Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
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Where we need to perform the contract we are about to enter into or have entered into with you
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Where we need to comply with a legal or regulatory obligation
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
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To write to advise how you might be able to benefit from a potential tax refund from an individual investment we have identified from publicly available sources (Companies House), on the grounds of our legitimate interests
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To allow us to present the maximum available tax refund claim to HMRC, we will require brief additional information from you once instructed, as this is necessary to for the Performance of our Contract with you. This personal data will include your income band (to determine if you pay tax at the basic or higher rate), whether you claimed EIS relief at the time on each investment and prices paid, and your national insurance number so HMRC can offset any loss against income tax paid. This personal data will be necessary to complete your tax refund claim to HMRC.
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After you claim has been concluded, we will retain your data for a period of 6 years. We do this in case your information is required after the completion of the claim. For example, if new documentary evidence or legal grounds come to light to further support your claim, it may be possible to appeal the original amount and obtain an additional tax refund on the grounds of our legitimate interests
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We may also need to share this information with HMRC or the ICO in the course of a routine audit, in order to comply with a legal or regulatory obligation
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Whilst we hold your personal data, we may contact you on the grounds of our legitimate interests should new developments arise that may affect you and we can advise you on how you might be able to benefit.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities from our data privacy manager.
Performance of Contract means processing your data where it is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
The Service we offer
As part of our service, we review and collect data from standalone investments in companies from publicly available sources (Companies House) where information is made public as a matter of law. Data protection and privacy laws allow us to collect and process personal information where this is necessary for the purposes of the legitimate interests of our business to enable us to give you the best service in a way which might reasonably be expected and which does not materially impact your interests, rights and freedoms. This would apply where we have identified a potential tax refund and contact you to advise how you might be able to benefit.
This privacy notice is provided in a layered format, so that key information about our service and Your Legal Rights in relation to our service are highlighted in the Introduction. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Your Legal Rights & Freedoms
Where we are processing your personal data on the grounds of our legitimate interests, you may request that we stop using your data due to your specific circumstances and wishes, or you may request that we stop using your personal data for some or all direct marketing channels if you do not wish to receive any further future communications, by opting out using the reply paid envelope or other method of communication below, and we must comply with your request.
INTRODUCTION
OUR PRIVACY NOTICE
Controller
Vintcent & Company Limited is the controller and responsible for your personal data (collectively Vintcent & Company, “we”, “us” or “our”).
Our Privacy Notice
Our full details are:
Full name of legal entity: Vintcent & Company Limited
Data privacy manager: Mr Oliver Vintcent
Email address: ovintcent@vintcentandco.com
Postal address: Eagle Tower, Montpellier Drive, Cheltenham GL50 1TA
Telephone number: 01242 232 288
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in February 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect various personal data, including the following:
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Details of the specific investment which is the basis of your potential tax refund claim
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Details of your contact with us via phone, email and post (for example notes of conversations, details of the specific claim, details of any queries or complaints you make, how and when you contact us)
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Your name, address, age, phone number and email address
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Copies of documents you provide as proof of your address or identity where required by law (for example copies of your passport and drivers licence, which may include details of your full name, address, date of birth and nationality, and copy of a utility bill as proof of your address)
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Data collected by the use of cookies in your web browser (eg which pages you have viewed)
Third-Party processors
We do not use third parties to process personal information about you on our behalf.
Cookies
You can set your browser to refuse all browser cookies, or you can choose to disable cookies on our website using our cookie banner.
Disclosures of your personal data
We may have to share your personal data with a party under our supervision and control (eg consultant, company or entity we control), or with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
International Transfers
We do not transfer your personal data outside the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
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. So after your claim is concluded, we will normally retain your personal data for a period of 6 years.
Your legal rights
Under data protection laws, you have rights in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact the data privacy manager.
YOUR LEGAL RIGHTS
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Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
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Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
