Privacy policy

1. Who we are

Apona is online software for preparing and filing UK tax returns, run by [Company name], a company registered in England and Wales (company number [number]), with its registered office at [address]. In this policy, "we", "us" and "Apona" mean that company.

We're registered with the Information Commissioner's Office (ICO), registration number [ICO number].

If you have a question about this policy or your information, email [email protected].

2. If you're a client of an accountancy firm that uses Apona

Apona is used in two ways:

• By people preparing their own return. Here, we decide how your information is used. We're the "controller" under data protection law, and this policy applies in full.
• By accountancy firms, for their clients. Here, your accountant is the controller of your information. We only process it on their instructions, to provide Apona to them. We're their "processor". Your accountant's own privacy notice explains how they use your information. Questions about it, or requests to see or change it, are best sent to them. If you contact us, we'll pass your request on to them.

We're the controller for the account details of everyone who signs in to Apona, including the staff of accountancy firms.

3. What we collect

Information you give us

• Account details: your name, email address, phone number, password (stored only in scrambled form) and your two-step sign-in set-up.
• Tax return information: whatever a return needs. This includes your Unique Taxpayer Reference, National Insurance number, date of birth and address, and your income, gains, expenses, reliefs and pension contributions. It can also include bank details for tax repayments.
• Documents: anything uploaded to support a return or an information request, such as P60s, statements and receipts.
• Practice records: for accountancy firms, details of your clients, their businesses and companies, tasks, notes, identity check records, engagement letters and the emails you send them through Apona.
• Billing details: the name, address and email for invoices. Card details go directly to our payment provider. We never see or store your full card number.
• Messages: anything you send us, such as support emails.

Sensitive information

Some answers on a tax return can reveal sensitive ("special category") information. For example, claiming Blind Person's Allowance reveals something about your health, and the Ministers of religion page relates to religious belief. We use this information only to prepare the return it was entered for. Where we're the controller, we rely on your explicit consent, which you give by entering it. You can remove it at any time, though the return may then be incomplete.

Information collected automatically

• Security and activity records: when you sign in, from which IP address and browser, and a log of changes made to clients and returns. This shows who changed what, and when.
• Technical logs: our servers record requests and errors so we can keep Apona running and secure.

This website (apona.co.uk) doesn't use analytics, tracking or advertising cookies.

Information from other people

• Your accountant, if they prepare your return or keep your records in Apona.
• Your employer or a colleague, if they invite you to join their firm's Apona account.
• Companies House, which publishes company details such as the names of directors and people with significant control.

Do you have to give us your information?

No, but without it we can't open your account or prepare a complete tax return.

4. How we use it, and why we're allowed to

We never sell personal information, and we never use it for advertising.

Apona works out tax automatically, using HMRC's published rules. It doesn't make decisions about you that have legal or similar effects: you, or your accountant, check every return before it's approved and filed.

5. Mailboxes connected from Google or Microsoft

Accountancy firms using the Practice add-on can connect their own Google (Gmail or Google Workspace) or Microsoft 365 / Outlook mailbox. Apona can then send emails to their clients from that mailbox. This is how it works.

What we ask for

• Google: permission to send email on your behalf (gmail.send), plus your email address so we can show which mailbox is connected.
• Microsoft: permission to send mail as you (Mail.Send), to read your basic profile (User.Read) for your name and email address, and to stay connected (offline_access).

With these permissions, Apona can send emails, but it can't read, search, change or delete anything in your mailbox.

How we use it

• We send only the emails that your firm writes or sets up in Apona, such as a reminder to a client. They're sent to the recipients your firm chooses, at the times your firm chooses.
• We store the sign-in token that Google or Microsoft gives us, encrypted in our database. We use it only to send those emails.
• We keep a copy of each email sent through Apona against the client's record, so your firm has a history of what was sent. It stays there until your firm deletes it or leaves Apona (see section 8).
• We don't use data from your mailbox for advertising or to train AI models, and we don't sell it or share it with anyone else.
• Our staff can't see your mailbox. They only see emails sent through Apona when your firm asks us to help with a problem, or when it's needed for security or the law.

Disconnecting

Press Disconnect on Apona's Email set-up page at any time. We delete the stored token straight away and, for Google, ask Google to withdraw it. You can also remove Apona's access from your Google Account or from your Microsoft account (personal accounts, or My Apps for work accounts). Your IT administrator can also remove it for a work account.

6. Who we share it with

We use a small number of trusted suppliers to run Apona:

• a cloud hosting provider, which runs Apona and holds its database in the UK (London)
• an email delivery service, which sends Apona's own emails, such as sign-in emails, invitations and emails sent "from Apona"
• a payment provider, which takes card payments
• a provider that runs our domain names and this website

They can only use your information to provide their service to us, under contracts that require them to protect it. Accountancy firms that use Apona can see the full list of these suppliers in our terms. Anyone else can ask us for it.

We also share information with:

• HMRC, when you or your accountant file a return or use another HMRC service through Apona. This includes some technical details HMRC asks for to help prevent fraud.
• Companies House, when you look up a company. We send the name or number you searched for.
• Google or Microsoft, if your firm connects a mailbox (see section 5).
• Your accountancy firm, if you share your return with them.
• Professional advisers and authorities, where the law requires it or to protect our rights.
• A buyer of our business, if Apona is ever sold. They would have to protect your information in the same way.

7. Information sent outside the UK

Apona's database is in the UK. Some of our suppliers are based in the United States, or have support staff there. When personal information is sent outside the UK, we make sure it stays protected. We rely on the UK's adequacy regulations (including the UK-US data bridge) or the ICO's approved contract terms (the International Data Transfer Agreement or Addendum).

8. How long we keep it

• Your account and returns: for as long as your account is open, so you can see earlier years. HMRC expects people to keep records for up to five years after the filing deadline.
• After you close your account: we delete your returns and documents within [90 days]. We keep only what the law requires us to keep.
• Billing records: six years after the end of the financial year they relate to, as tax law requires.
• Security and activity logs: [12 months], then deleted.
• Backups: deleted information is removed from our backups within [7 days].
• Accountancy firms' client data: kept and deleted as the firm instructs. When a firm leaves Apona, we delete its data within [90 days], after giving it the chance to download it.

9. Keeping it safe

• All connections to Apona are encrypted.
• Tax references, National Insurance numbers and mailbox tokens are encrypted again in our database.
• Every account uses two-step sign-in, and you're signed out after 30 minutes without activity.
• Staff at accountancy firms only see what their role allows, and every change is logged.
• Only a small number of our own people can access live data, and only when it's needed to support you or keep Apona running.

If something ever went wrong that put your information at risk, we'd tell you and the ICO as the law requires.

10. Cookies

The Apona app uses only the cookies it needs to work:

• a cookie that keeps you signed in
• a cookie that protects forms against forgery

Because they're essential, they don't need your consent. We don't use analytics, tracking or advertising cookies, in the app or on this website.

11. Your rights

You have the right to:

• get a copy of the personal information we hold about you
• have it corrected if it's wrong
• have it deleted, unless we need to keep it by law
• ask us to limit how we use it, or object to how we use it
• receive it in a format you can take elsewhere
• withdraw your consent, where we rely on it

To use any of these rights, email [email protected]. It's free, and we'll reply within one month. If your information is held for an accountancy firm, we'll pass your request to them (see section 2).

If you're unhappy with how we've handled your information, please tell us first so we can put it right. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

12. Changes to this policy

We'll update this policy when Apona changes. If a change affects how we use your information, we'll tell you by email or in Apona before it takes effect. The date at the top shows when it was last updated.

Questions? Email [email protected].