1. Who we are
This policy explains how ALTERA SERVICES LTD ("Altera", "we", "us") collects and uses personal data when you visit www.alteraservices.co.uk, contact us, or use our services.
ALTERA SERVICES LTD is a company registered in England and Wales, company number 11098816. Registered office: 71–75 Shelton Street, London, WC2H 9JQ.
We are the controller of your personal data and are registered with the Information Commissioner's Office (ICO), registration number ZB709773.
For any question about this policy or your data, contact us at info@alteraservices.co.uk or at the address above.

2. The data we collect
When you use our website

• Name, email address and phone number you enter in our forms (for example, to request a brochure or book a call).
• Technical data such as IP address, browser type, device and pages visited, collected through cookies. See our Cookie Policy.

When you become a client, or act for a client company
We are supervised by HMRC under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("the MLRs") and act as a Companies House Authorised Corporate Service Provider. We must identify and verify our clients and the people behind them. This means we collect:

• Identity data: full name, date of birth, nationality, residential address, copies of identity documents and proof of address.
• Company data: details of directors, shareholders, persons with significant control and beneficial owners.
• Verification data: results of electronic identity checks and, where used, a selfie or video compared against your ID document (facial comparison).
• Screening data: results of sanctions, politically exposed person (PEP), watchlist and adverse media checks.
• Source of funds and source of wealth information, where required.
• Contact, billing and payment details, and records of the services we provide.

Facial comparison involves biometric data, and screening may reveal information about alleged or proven criminal offences. We process this only where required for identity verification and anti-money laundering compliance, and only as permitted by the Data Protection Act 2018.

3. How we collect it

• Directly from you, through our website forms, email, phone, and documents you send us.
• From identity verification and screening providers we use for customer due diligence.
• From public sources such as the Companies House register.
• From professional introducers who instruct us on behalf of their own clients.

4. How we use it and our lawful basis

• Responding to enquiries and brochure requests — Legitimate interests (responding to people who contact us)
• Providing our services, including company formation, filings and document legalisation — Performance of a contract
• Identity verification, customer due diligence and ongoing monitoring — Legal obligation (the MLRs; Companies Act 2006 identity verification rules)
• Facial comparison and screening for criminal offence data — Substantial public interest: preventing and detecting unlawful acts and regulatory requirements (Data Protection Act 2018, Schedule 1)
• Invoicing, accounting and tax records — Legal obligation and performance of a contract
• Reporting suspicious activity to the National Crime Agency where required — Legal obligation
• Sending you updates about our services — Legitimate interests, or consent where the law requires it. You can opt out at any time
• Website analytics — Consent, given through our cookie banner

We do not sell your personal data. We do not use it for automated decisions that have legal or similarly significant effects on you without human review.

5. Who we share it with

• Service providers acting on our instructions: website hosting and forms (Tilda), email and document storage (Google), client records (Airtable), and identity verification and AML screening (Didit, TrustID).
• Professional partners where needed to deliver your instruction: UK solicitors, notaries public, certified translators, embassies and consulates, and regulated immigration solicitors.
• Authorities: Companies House, HMRC, the National Crime Agency and other regulators or law enforcement bodies where the law requires it.
• Introducers who instructed us on your behalf, to the extent needed to complete the work.

We may be legally prohibited from telling you that we have made a report to the authorities.

6. International transfers
Some of our service providers store or process data outside the UK. Where this happens, we rely on UK adequacy regulations or on appropriate safeguards such as the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Contact us for more details.

7. How long we keep it

• Customer due diligence records and records of transactions: 5 years from the end of our business relationship with you, as required by the MLRs, unless the law requires or allows us to keep them longer.
• Accounting and tax records: 6 years from the end of the financial year they relate to.
• Website enquiries that do not lead to an engagement: up to 24 months from your last contact with us.

After these periods we securely delete or anonymise the data.

8. Security
We restrict access to personal data to staff and providers who need it, use secure systems with access controls, and have procedures for handling suspected data breaches, including notifying you and the ICO where the law requires.

9. Your rights
You have the right to:

• access the personal data we hold about you;
• ask us to correct inaccurate data;
• ask us to delete your data;
• object to or ask us to restrict certain processing;
• ask us to transfer your data to you or another organisation;
• withdraw consent at any time, where we rely on consent.

Some rights are limited where we must keep data by law, for example customer due diligence records under the MLRs.
To exercise any right, email info@alteraservices.co.uk. We may need to verify your identity first. We aim to respond within one month and do not usually charge a fee.

10. Complaints
If you are unhappy with how we handle your data, please contact us first. You also have the right to complain to the Information Commissioner's Office at www.ico.org.uk or on 0303 123 1113.

11. Changes to this policy
We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.