Privacy Policy

  LEGALEZE LIMITED

Data privacy notice

1. Introduction

1.1. We take seriously the privacy of our customers, website users and other individuals whose personal data we process. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint. 

1.2. This privacy policy does not apply to any third party websites which may have links to our own website.

2. Who are we and what do we do?

2.1. For more information about our business, please consult our website at https://www.legaleze.co.uk/  or Contact us (see section 13). We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

2.2. Our services and website are not aimed specifically at children. If you are a child and you want further information about how we might use your data, please contact us (see ‘Contact us’ in section 13).

2.3. Key terms

Key terms used in this notice are as follows:  

We, us, our:Legaleze Limited   (incorporated in England and Wales under company no. 07401414) 

Personal data: Any information relating   to an identified or identifiable individual 

Special category personal   data: Personal data revealing   racial or ethnic origin, political opinions, religious beliefs, philosophical   beliefs or trade union membership

Genetic data: Biometric data (where used   for identification purposes)

Data concerning health,   sex life or sexual orientation 

Data subject: The individual who the   personal data relates to

3. Personal data we collect about you

3.1. The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:

· your name and contact information, including email address and telephone number and company details;

· your address, for delivery purposes;

· information to check and verify your identity, e.g. your date of birth;

· your gender, if you choose to give this to us;

· location data, if you choose to give this to us;

· your billing information, transaction and payment card information;

· your personal or professional interests;

· your contact history, purchase history and saved items;

· information from accounts you link to us, e.g. Facebook;

· information to enable us to undertake credit or other financial checks on you;

· information about how you use our website, IT, communication and other systems;

· your responses to surveys, competitions and promotions.

3.2. We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

4. How your personal data is collected

4.1. We collect most of the above information from you. However, we may also collect information:

· from publicly accessible sources, e.g.: Companies House or HM Land Registry;

· directly from a third party, e.g. credit reference agencies;

· from a third party with your consent, e.g. your bank or building society, other financial institution or advisor;

· via our website—we use cookies and similar technologies on our website.

5. How and why we use personal data

5.1. Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

· you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;

· to comply with our legal and regulatory obligations;

· to fulfil our contract with you or take steps at your request before entering into a contract; or

· for our legitimate interests or those of a third party.

5.2. A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.

5.3. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.

5.4. The table below explains what we use your personal data for and why:   

What we use your personal data for

Our reasons: 

*Providing services to you

*To fulfil our contract   with you or to take steps at your request before entering into a contract 

*Preventing and detecting   fraud against you or us

*For our and/or your   legitimate interests, ie to minimise fraud that could be damaging for you   and/or us 

^Conducting checks to   identify our customers and verify their identityScreening for financial   and other sanctions or embargoes

*Other activities necessary   to comply with legal and regulatory obligations that apply to our business, e.g.   under health and safety law

*Depending on the   circumstances:

—to comply with our legal   and regulatory obligations

—for our legitimate   interests 

*To enforce legal rights or   defend or take legal proceedings

*Depending on the   circumstances:

—to comply with our legal   and regulatory obligations

—for our legitimate   interests, ie to protect our business, interests and rights 

*Gathering and providing   information required by or relating to audits, enquiries or investigations by   regulatory bodies

*Depending on the   circumstances:

—to comply with our legal   and regulatory obligations

—for our legitimate   interests 

*Ensuring internal business   policies are complied with, e.g. policies covering security and internet use

*For our legitimate   interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you 

*Ensuring the   confidentiality of commercially sensitive information

Depending on the   circumstances:

—for our legitimate   interests, i.e. to protect trade secrets and other commercially valuable   information

—to comply with our legal   and regulatory obligations 

*Statistical analysis to   help us manage our business, e.g. in relation to our financial performance,   customer base, services range or other efficiency measures 

*Protecting the security of   systems and data used to provide services, prevent unauthorised access and   changes to our systems

Depending on the   circumstances:

—for our legitimate   interests, i.e. to prevent and detect criminal activity that could be   damaging for you and/or us

—to comply with our legal   and regulatory obligations 

*Updating and enhancing   customer records

Depending on the   circumstances:

—to fulfil our contract   with you or to take steps at your request before entering into a contract

—to comply with our legal   and regulatory obligations

—for our legitimate   interests, e.g. making sure we can keep in touch with our customers about   existing and new services 

*Statutory returns

*To comply with our legal   and regulatory obligations 

Ensuring safe working   practices, staff administration and assessments

Depending on the   circumstances:

—to comply with our legal   and regulatory obligations

—for our legitimate   interests, e.g. to make sure we are following our own internal procedures and   working efficiently so we can deliver the best service to you 

*Marketing our services and   those of selected third parties to existing and former customers

Depending on the   circumstances:

—for our legitimate   interests, i.e. to promote our business

—consent (which we will   ask for separately) 

*Credit reference checks   via external credit reference agencies

For our legitimate   interests, i.e. to ensure our customers are likely to be able to pay for our   services 

*External audits and   quality checks, e.g. for ISO or Investors in People accreditation and the   audit of our accounts (to the extent not covered by ‘activities necessary to   comply with legal and regulatory obligations’ above)

Depending on the   circumstances:

—for our legitimate   interests, i.e. to maintain our accreditations so we can demonstrate we   operate at the highest standards

—to comply with our legal   and regulatory obligations

To share your personal   data with members of our group and third parties that will or may take   control or ownership of some or all of our business (and professional   advisors acting on our or their behalf) in connection with a significant   corporate transaction or restructuring, including a merger, acquisition,   asset sale or in the event of our insolvency.

In such cases information   will be anonymised where possible and only shared where necessary.

Depending on the   circumstances:

—to comply with our legal   and regulatory obligations

—in other cases, for our   legitimate interests, ie to protect, realise or grow the value in our   business and assets

5.5. Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws e.g.:

• we have your explicit consent;

• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; 

• the processing is necessary to establish, exercise or defend legal claims; or

• the processing is necessary for reasons of substantial public interest.

· Marketing: We may use your personal data to send you updates (e.g. by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent. In all cases, you have the right to opt out of receiving marketing communications at any time by contacting us – Contact us at section 13.

5.6. We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

5.7. We will always treat your personal data with the utmost respect and never sell it to OR share it with organisations outside our group (see section 6.1) for marketing purposes except in connection with the sale of the whole or a substantial part of our business and subject to giving you notice of such sale.

6. Who we share your personal data with

6.1. We may share personal data with:

· Our holding company and any subsidiary of our holding company;

· third parties we use to help deliver our services to you, e.g. providers of our finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;

· companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;

· other third parties we use to help promote our business, e.g. marketing agencies;

· third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;

· our bankers.

6.2. We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.

6.3. We or the third parties mentioned above may occasionally also share personal data with:

· our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations

· our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

· law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

· other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

7. Where your personal data is held

7.1. Personal data may be held at our premises and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

7.2. Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad’.

8. How long your personal data will be kept

8.1. We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

8.2. If you no longer have an account with us or we are no longer providing goods or services to you, we will usually delete or anonymise your account data after seven years.

8.3. Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

9. Transferring your personal data abroad

9.1. It may be sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. This may include countries which do not provide the same level of protection of personal data as the UK or EEA.

9.2. We will transfer your personal data outside the UK and EEA only where:

· the UK government[or European Commission has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or

· there are appropriate safeguards in place (e.g. standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or

· a specific exception applies under data protection law.

9.3. You can contact us (see ‘How to contact us’ below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of personal data when it is transferred abroad.

10. Your data protection rights

10.1. You have the following rights, which you can exercise free of charge:  

* Access

The right to be provided   with a copy of your personal data  

*Rectification

The right to require us to   correct any mistakes in your personal data 

*Erasure (also known as the   right to be forgotten)

The right to require us to   delete your personal data—in certain situations 

*Restriction of processing

The right to require us to   restrict processing of your personal data—in certain situations, e.g. if you   contest the accuracy of the data 

*Data portability

The right to receive the   personal data you provided to us, in a structured, commonly used and   machine-readable format and/or transmit that data to a third party—in certain   situations 

*To object

The right to object:

—at any time to your   personal data being processed for direct marketing (including profiling);

—in certain other   situations to our continued processing of your personal data, e.g. processing   carried out for our legitimate interests unless we demonstrate compelling   legitimate grounds for the processing which override your interests or for   establishing, exercising or defending legal claims 

*Not to be subject to   automated individual decision making

The right not to be   subject to a decision based solely on automated processing (including   profiling) that produces legal effects concerning you or similarly   significantly affects you 

*The right to withdraw   consent

If you have provided us   with a consent to use your personal data you have a right to withdraw that   consent at any time

You may withdraw consents   by [insert details as relevant depending on consents

Withdrawing consent will   not affect the lawfulness of our use of your personal data in reliance on   that consent before it was withdrawn

10.2. If you would like to exercise any of those rights, please:

· email, call or write to us—see Contact us in section 13; and

· provide enough information to identify yourself (e.g.. your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you;

· let us know what right you want to exercise and the information to which your request relates.

11. Keeping your personal data secure

11.1. We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. 

11.2. We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

11.3. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

12. How to complain

12.1. Individuals in the UK: You can contact us[ and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

12.2. You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address: 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk 

13. Contact us

Our contact details are shown below:   

· Post: 95   Mortimer Street, London W1W 7GB: 

· Email: a.farmiloe@legaleze.co.uk

14. Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘Contact us’ in section 13.