Effective Date: 2026-05-29 · Version 1.0
1. Scope
This notice supplements our Privacy Policy and applies whenever a person located in the European Economic Area, the United Kingdom, or Switzerland interacts with troyaccounting.tax or with our firm. It explains our role, our lawful bases, your rights, and contacts.
2. Our Role
For information you submit through our website or instant quote tool, Troy Accounting acts as the data controller. For client engagement work (bookkeeping, tax, payroll, advisory) where we process personal data on behalf of a client business, Troy Accounting acts as a data processor under a separately-executed engagement letter or Data Processing Agreement.
3. Lawful Bases
We process personal data on one of these GDPR Article 6 lawful bases: Consent (cookies you accept, newsletter sign-ups), Contract (delivering the services you have engaged us for), Legitimate interests (responding to inquiries, securing our systems, defending legal claims, improving the website), Legal obligation (tax records retention, AML compliance, court orders), Vital interests (rare; protecting safety).
4. Your Rights
You have the right to access, rectify, erase (subject to our legal obligations to retain certain records), restrict, port, object to processing, and withdraw consent where consent is our basis. You may also lodge a complaint with your supervisory authority. To exercise any right, email info@troyaccounting.net with sufficient detail to verify your identity.
5. Retention
Marketing inquiries: 24 months. Client engagement records: 7 years after engagement end (tax / professional standards). Web analytics: 26 months in aggregated form. After retention, data is securely deleted or anonymized.
6. International Transfers
Our infrastructure is U.S.-based. Where we transfer personal data from the EEA, UK, or Switzerland to the U.S., we rely on Standard Contractual Clauses (SCCs) and supplementary measures including encryption in transit and at rest, access controls, and audit logging.
7. Automated Decisions
We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on you.
8. Data Protection Contact
EU/UK queries: info@troyaccounting.net. For complaints, you may contact your national supervisory authority. UK residents may contact the ICO (ico.org.uk).