Change in Policies - May 2018 No Images? Click here Change in PoliciesMay 25 2018 Data Protection and Privacy PoliciesMir Taxes LLCMir Taxes LLC (“Mir Taxes LLC” “we”, “our”, “us”) is committed to ensuring that your personal data is used correctly and in accordance with the highest standards of Data Protection Law.This Privacy Policy (“Policy”) explains in detail the types of personal data we may collect about you and what we do with your personal data. It also set outs what we do to keep your personal data secure, as well as your rights in relation to the personal data we hold about you. Please see the “Definitions and Glossary” section to understand the meaning of some of the terms used in this Policy. What personal data do we collect? · Information you provide us when you use our Services or contact our team: · Personal details such as your name, gender, address, date of birth, telephone number, email address and social security number. · Copies of documents you provide to prove your age or identity. For example, your passport, driving license, marriage certificate and utility bill. · Copies of documents you provide to prove your source of funds. For example, your bank statement or pay slip. · Bank account and payment card details Information we collect about you when you use our Services or contact our team: · Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates. · We will update the information we hold on you as and when you provide it to us during our communications with you. However, whenever possible, you should advise us if information we hold on you needs updating or is no longer accurate. Information we collect about you when you use our Services or contact our team: · When you visit any of our websites or download documents to the Mir Taxes LLC sites, including Intuit Link. · When you make an enquiry about our Services or open an account with us online, over the telephone, by post or in person. When you make international payments online, over the telephone, by post or in person. · During business-to-business correspondence over telephone, email, post or in person. · The “lawful basis” we rely on to process your personal data Data Protection Law sets out six lawful basis that organizations, businesses and governments can rely on to collect and process personal data. Mir Taxes LLC predominately relies on the following: 1. Consent - This means processing your personal data where you have explicitly given us permission to do so. 2. Performance of a Contract (“Engagement Letter”)- This means processing your personal data in order to fulfil our contractual obligations with you. 3. Legal Obligations - This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject. 4. Legitimate Interests - This means processing your personal data where we have a legitimate interest to do so. We make sure we consider and balance any potential impact on your rights before we process your personal data for our legitimate interests. Where our interests are overridden by a negative impact on your rights, we will not process your personal data. 5. How do we use your Personal Data? - We may process your personal data for the following purposes, depending on how you interact with us. 1. To complete the delivery of our US reporting services (“Services”) Without your personal data, we would not be able to complete the US tax returns or FBARs and complete the delivery of our services. 2. To respond to your queries and complaints. Without your personal data, we would not be able to effectively respond and handle queries or complaints. We may keep a record of our correspondence to demonstrate how we communicated with you throughout. We will do this on the basis of our legitimate interests and our legal obligations. 3. To comply with our legal and regulatory obligations In order to meet our legal and regulatory requirements, we are required to carry out regulatory checks in order to prevent and detect fraud, money laundering, identity theft and other crimes. We are also required to send you communications known as ‘service messages’ in order to inform you about changes to the services we provide you. These service messages will not include any promotional content and cannot be unsubscribed from. 4. To analyze, test and improve our systems and databases We may use your personal data to ensure that our systems are tested thoroughly. This ensures that the system can cope with comparable volumes of information, that a wide range of realistic scenarios are covered, and that the test will reflect all the possible combinations that occur in the real environment. Test systems are isolated from external networks to ensure that live systems are not compromised. In addition, to ensure data is not compromised, we carry out various risk assessments, and have implemented safeguards to ensure data security. We will do this on the basis of our legitimate interests. 5. For training and quality purposes We are continually reviewing the quality of the services we provide in order to improve your experience with Mir Taxes LLC. We will do this based on our legitimate interests. 6. To keep you informed about relevant market and tax news. For our clients, we will only keep you informed about relevant tax and market news. You are free to opt out of receiving communications from us at any time by “unsubscribing” the newsletters. 6. Who do we share your personal data with? We may share your personal data with the following entities for the purposes described in this Policy: 1) Mir Taxes LLC subsidiaries, branches, and affiliate companies 2) Public authorities: With only your authorization in sending data or responding to inquiries from the Internal Revenue Service (IRS), U.S. Department of Treasury (USDT) or individual state tax authorities. This will only be in response to lawful requests made from public authorities in order to meet national security, public interest, or law enforcement requirements. 3) Other third parties With your consent only, we may pass your data to a third party per your instructions only. If you have been referred to Mir Taxes LLC by a third party who you have a direct relationship with (e.g. an estate agent or an Independent Financial Advisor), we may provide such third party with personal data relating to you in which they are interested in by virtue of Mir Taxes LLC’s agreement with them and where your interests and data protection rights do not override those interests. Please note our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites. 1. Sharing your personal data outside the European Economic Area The personal data that we collect from you may be transferred to, and stored at, destinations both in and outside the European Economic Area (“EEA”). Where processed outside the EEA, we will take appropriate steps to ensure your personal data still receives a level of protection that is consistent with European data protection standards. For example, we will only share your personal data outside the EEA if we have an EU approved model clauses agreement in place or if the third party receiving your personal data has signed up to an EU approved data sharing mechanism such as the EU-US Privacy Shield scheme. 2. How do we protect your personal data? We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Personal data is protected by a defense in depth security programme that is aligned to best practice found in International Organization for Standardization (ISO 20071) and National Institute of Standards Technology (NIST) documentation. Protections include, but are not limited to, mature access control (with strict procedures around privileged access), network segmentation, standard security appliances (firewalls, IPS, AV, monitoring via SIEM), secure configuration and system hardening, monthly vulnerability assessments and yearly penetration tests, documented processes, and procedures, DLP protection, rogue detection, and monthly rolling patch management and vulnerability remediation. We also secure access to all transactional areas of our websites and apps using ‘https’. We provide our employees with training and detailed information about our data handling practices through internal company policies such as our Data Protection Policy. All employees must certify that they have read and understood the contents of our Data Protection Policy where is reviewed and updated on an annual basis. As well as our data protection policy, which governs how we process data throughout the Mir Taxes LLC, we have a separate suite of internal policies which govern areas such as information security and information classification. 3. How long will we keep your personal data? Whenever we collect or process your personal data, we will only keep it for the purpose for which it was collected and in accordance with our legal and regulatory obligations. In most cases, our retention period for your personal data will come to an end ten years after the end of your relationship with us. Closed Accounts If you inform us you longer wish to have a Mir Taxes LLC account, we will close and deactivate your account. At the end of the retention period, your personal data will either be anonymized (so that it can only be used in a non-identifiable way for statistical analysis, business planning), made inaccessible or unintelligible (for system integrity purposes) or deleted completely. Your Data Protection Rights You have a number of rights under Data Protection Law which, in certain circumstances, you may be able to exercise in relation to the personal data we process about you. This includes: Right to Access: You have a right to receive a copy of the personal data we hold about you. This is commonly known as a Data Subject Access Request. Right to Data Portability: You have a right to receive certain information you have provided to us in a ‘machine-readable’ format and/or request that we transmit it to a third party. Right to Erasure: You have a right to request that we erase your personal data. However, 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. Right to Object: In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data. Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection authority. Further details can be found in the “Contact Us” section of this Policy. Right to Rectification: Where your personal data is inaccurate, out-of-date, or incomplete, you have the right to request an amendment to it. Right to Withdraw Consent: Where you have given us your consent to process your personal data, you have the right to change your mind at any time and withdraw that consent. If you wish to exercise any of these rights, please get in touch by using the details in the “Contact” section below. Please note we will ask you to verify your identity before proceeding with any request you make. Managing your Mir Taxes LLC marketing preferences There are a number of ways you can update or stop direct marketing communications from us: Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular business entity of Mir Taxes LLC. Email: info@mirtaxes.com or call +32 494 27 97 63 or +1 (919) 960-1499. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. Contact You can direct any questions or complaints about the use or disclosure of your personal data to us at: Email: info@mirtaxes.com Telephone: Europe: +32 (0)494 27 97 63 or US: +1 (919) 960-1499 Post: Rue de la Presse 4, Brussels 1000 Belgium or 9204 NW 73rd Street, Tamarac FL 33321 USA If you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the relevant data protection authority in your country of residence. For other matters, contact us via email info@mirtaxes.com. Changes Effective Date: 25th May 2018 Last Modified: 25th May 2018 We reserve the right to amend this Policy from time to time in order to be consistent with Data Protection Law requirements. Where we do make significant changes to this Policy, we will take appropriate steps to bring those changes to your attention. Glossary and Definitions Data Protection Law This means the EU General Data Protection Regulation 2016/679 (as amended and replaced from time to time), the EU Privacy and Electronic Communications Directive 2002/58/EC (as amended by Directive 2009/136/EC and as amended from time to time) and any national implementing legislations (as amended and replaced from time to time). European Economic Area The means the countries of the European Union and members countries of the European Trade Association. A complete list of applicable countries can be found at: https://www.gov.uk/eu-eea Mir Taxes LLC Personal Data This means information that can be used to directly or indirectly identify a living person. Process, Processing, Processed This means operation or set of operations which are performed on data. This includes collecting, viewing, recording, organizing, structuring, storing, using, and destroying. Referring Partner This means an entity who has referred an individual or company to Mir Taxes LLC in order to engage in our services. They are also known as Introducers and include property agents, law firms, financial accountants, and banks. Services This means US tax return preparation, USDT reporting, US tax advice, and other services provided by Mir Taxes LLC companies.
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