Privacy Notice

  1. ScopeAll data subjects whose personal data is collected, in line with the requirements of the GDPR.
  2. Responsibilities
    1. The Data Protection Officer/GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Floating Cloud Ltd T/A Modina collecting/processing
      their personal data.
    2. All employees/staff of Floating Cloud Ltd T/A Modina who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
  3. Privacy Notice
      1. Who are we?

        Floating Cloud Ltd T/A Modina are a firm of bookkeeping and payroll advisers. The services we offer are as follows:

        – Financial management
        – Financial information systems – Computer systems advice
        – HM Revenue and Customs investigations
        – Value Added Tax – PAYE and national insurance compliance
        – Preparation of annual accounts
        – Preparation of periodic management accounts
        – Providing bookkeeping services
        – Maintaining PAYE and VAT records and associated returns
        – Preparation and filing of statutory returns
        – Preparation of minutes and resolutions
        – Company formation
        – Company searches

        Our Data Protection Officer/GDPR Owner and data protection representatives can be contacted directly here:

        Sharon Mordecai –

        0207 183 8241

        The personal data we would like to collect and process on you is:

        Personal data type: Source
        Name, address, telephone number, email address, Unique Tax Reference number (UTR), national insurance number, bank account details.
        Details of your investments.
        Income and expenditure details.
        Your IP address.
        These details will all be collected directly from you or your appointed representative.

        The personal data we collect will be used for the following purposes:

        • Contact you by post, email or telephone.
        • Maintain our records in accordance with applicable legal and regulatory obligations.
        • Process financial transactions to produce accounts and tax returns, bookkeeping and payroll.

        Our legal basis for processing for the personal data:

          • Are to assist you as appointed agents to help you fulfill your legal responsibilities, with regards to the filing of bookkeeping and payroll.
      2. ConsentBy consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.Consent is required for Floating Cloud Ltd T/A Modina to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

        You may withdraw consent at any time by contacting Floating Cloud Ltd T/A Modina using the contact details in 3.1.

      3. DisclosureFloating Cloud Ltd T/A Modina will not pass on your personal data to third parties without first obtaining your consent.We may pass your information to our third party service providers and agents for the purposes of completing tasks and providing services to you on our behalf, for example to enable bookkeeping and ensure you are kept up to date. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep the information secure and not to use it for their own purposes.
      4. Retention PeriodWe are required by legislation, other regulatory requirements and our insurers to retain our data where we have ceased to act for you. To ensure compliance with all such requirements it is the policy of the firm to retain data for a period of seven years from the end of the period concerned. If for any legal reason your data is held past this time, you will be informed of the extension.
      5. Yours Rights as a Data SubjectAt any point while we are in possession of or processing your personal data you, the data subject, have the following rights:
        • Right of access – you have the right to request a copy of the information that we hold about you.
        • Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete.
        • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
        • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
        • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
        • Right to object – you have the right to object to certain types of processing such as direct marketing.
        • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
        • Right to judicial review: in the event that Floating Cloud Limited T/A Modina refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.


      1. ComplaintsIn the event that you wish to make a complaint about how your personal data is being processed by Floating Cloud Ltd T/A Modina, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Floating Cloud Ltd T/A Modina’s data protection representatives Data Protection Officer/GDPR Owner.The details for each of these contacts are:
        Supervisory authority
        contact details
        Data Protection Officer (DPO) contact details
        Contact Name: Information Commissioners Office Sharon Mordecai at Floating Cloud Ltd T/A Modina
        Address line 1: Wycliffe House 62 Wilbury Way
        Address line 2: Water Lane
        Address line 3: Wilmslow Hitchin
        Address line 4: Cheshire Hertfordshire
        Address line 5: SK9 5AF SG4 0TP
        Telephone: 0303 123 1113 0207 183 8241


    1. Privacy StatementRead more about how and why we use your data at
  4.  Online Privacy StatementPersonal dataUnder the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

    “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, metal, economic, cultural or social identify of that natural person”.

    How we use your information

    This privacy notice tells you how we, Floating Cloud Limited T/A Modina, will collect and use your personal data for the performance of our services to you under 3.1.

    Why does Floating Cloud Ltd T/A Modina need to collect and store personal data?

    In order for us to provide you with our services we need to collect personal data for correspondence purpose and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

    In terms of being contacted for marketing purposes Floating Cloud Limited T/A Modina would contact you for additional consent.

    Will Floating Cloud Limited T/A Modina share my personal data with anyone else?

    We may pass your personal data on to third party service providers contracted to Floating Cloud Limited T/A Modina in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide you on our behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with Floating Cloud Limited T/A Modina procedures. If we wish to pass your sensitive personal data on to a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

    How will Floating Cloud Ltd T/A Modina use the personal data it collects about me?

    Floating Cloud Ltd T/A Modina will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR).

    We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Floating Cloud Ltd T/A Modina is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

    Under what circumstances will Floating Cloud Ltd T/A Modina contact me?

    Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

    Can I find out the personal data that the organisation holds about me?

    Floating Cloud Ltd T/A Modina at your request, can confirm what information we hold about you and how it is processed. If Floating Cloud Ltd T/A Modina does hold personal data about you, you can request the following information:

      • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
      • Contact details of the data protection officer, where applicable.
      • The purpose of the processing as well as the legal basis for processing.
      • If the processing is based on the legitimate interest of Floating Cloud Ltd T/A Modina or a third part, information about those interests.
      • The categories of personal data collected, stored and processed.
      • Recipient(s) or categories of recipients that the data is/will be disclosed to.
      • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
      • How long the data will be stored.
      • Details of your rights to correct, erase, restrict or object to such processing.
      • Information about your right to withdraw consent at any time.
      • How to lodge a complaint with the supervisory authority.
      • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
      • The source of personal data if it was not collected directly from you.
      • Any details and information of automated decision making, such as profiling and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

    What forms of ID will I need to provide in order to assess this?

    Floating Cloud Limited T/A Modina accepts the following forms of ID when information on your personal data is requested:

    Passport, driving licence, birth certificate, utility bill (from the last three months).

    Contact details of the Data Protection Officer/GDPR Owner:

    Data Protection Officer/GDPR Owner contact details
    Contact name: Sharon Mordecai
    Address line 1: 62 Wilbury Way
    Address line 2: Hitchin
    Address line 3: Hertfordshire
    Address line 4: SG4 0TP
    Address line 5:
    Telephone: 0207 183 8241

    Document Owner and Approval

    The Data Protection Officer/GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

    A current version of this document is available to all members of staff.

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