Privacy Policy

Why this notice exists

This notice supplements the main Privacy Policy above. It specifically explains how we handle health and disability information when you apply for VAT Relief on mobility equipment.

If you have not applied for VAT Relief, this notice does not apply to you — please refer to the main Privacy Policy.

Who we are

ComfyGO Ltd
80 Tanners Dr, Blakelands
Milton Keynes MK14 5BP
United Kingdom

Email: info@comfygomobility.co.uk
Phone: 0330 520 0720

ComfyGO Ltd is the data controller for the information described in this notice.

What information we collect

When you apply for VAT Relief, we collect:

• A declaration that you have a chronic illness or disability, as defined by HMRC
• The name of your chronic illness or disability (self-declared only — no medical evidence required)
• Your name and address, linked to your order
• The signed declaration (digitally or on paper)
• Date of declaration

This is "special category data" under UK GDPR Article 9. We take extra care when processing it.

Our legal basis for processing

We process this information under Article 9(2)(b) of UK GDPR, which permits the processing of special category data where necessary for compliance with obligations under social protection law.

Specifically, HMRC Notice 701/7 requires us to collect and retain eligibility declarations from customers purchasing mobility equipment VAT-free. Without this information, we cannot lawfully supply the product at the VAT-free price.

Why we need this information

The only purposes for which we collect and process your VAT Relief information are:

• To verify your eligibility for VAT Relief under HMRC rules
• To apply the correct (VAT-free) pricing to your order
• To maintain records in case HMRC audits our VAT Relief transactions
• To comply with our legal obligations under the Value Added Tax Act 1994 and related regulations

We do not use this information for marketing, analytics, profiling, or to make automated decisions about you.

Who we share this with

We share your VAT Relief declaration only with:

• HMRC — if specifically requested as part of a VAT audit, and only the declarations relevant to that audit

We do not share your health or disability information with:

• Advertising or marketing platforms (Google, Meta, etc.)
• Analytics providers
• Third-party service providers beyond HMRC
• Any other retailer, manufacturer, or organisation

Your payment processor (Shop Pay / PayPal) sees only the final VAT-free amount — not the reason for the VAT exemption.

How long we keep it

We retain VAT Relief declarations for 6 years following the end of the tax year in which they were issued.

This retention period is required by HMRC under the Value Added Tax Regulations 1995 (Regulation 31) for tax audit purposes.

After 6 years, declarations are securely deleted from our active systems and any backups.

Where we store it

Your VAT Relief declaration is stored within our Shopify backend in the United Kingdom and European Union (Shopify EU data centres). We do not transfer this data outside the UK/EU.

Your rights

Under UK GDPR, you have the right to:

• Access the VAT Relief information we hold about you
• Correct inaccurate information
• Request deletion from our active systems (see note below)
• Object to processing (though this may mean we cannot supply VAT-free pricing)
• Data portability — receive a copy of your declaration in a readable format
• Complain to the Information Commissioner's Office (ICO) at ico.org.uk

To exercise any of these rights, email us at info@comfygomobility.co.uk. We will respond within 30 days.

Note on deletion: Even if you request deletion, we are legally required under UK tax law to maintain VAT audit records for 6 years. We can delete your declaration from active marketing or customer systems, but audit records must be retained until the 6-year period ends.

Security

We protect your VAT Relief information with:

• Encrypted data transmission (HTTPS/TLS) when you submit the declaration
• Access controls restricting viewing to authorised ComfyGO staff
• Secure storage via Shopify's GDPR-compliant infrastructure
• Staff training on handling sensitive health data

Changes to this notice

We may update this notice to reflect changes in the law or our processes. When we make significant changes, we will notify customers who have submitted VAT Relief declarations by email.

Current version: April 2026.

Questions?

If you have any questions about this notice or how we handle your VAT Relief information, contact us:

Email: info@comfygomobility.co.uk
Phone: 0330 520 0720 (Mon-Fri, 9am-5pm)