Privacy Policy

BACKGROUND:

 

Legal Utopia understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, legalutopia.co.uk, (“Our Site”) and everyone who accesses our mobile application available from the Apple App Store (https://www.apple.com/uk/ios/app-store/) and the Google Play Store (https://play.google.com/store/apps?hl=en) (collectively “Our Apps”).

 

We will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law. Unless an applicable supplement policy expressly applies to a specific service or function.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested at the time of visiting Our Site or creating an Account on Our Apps.

  1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

 

Account” means an account required to access and/or use certain areas and features of Our Site or Apps;

"Artificial Intelligence Technology" means such advanced technologies known to use solely computational techniques and processing to emulate cognitive processes of a natural person to achieve the same or similar outcome(s);

Cookie”  means a small text file placed on your computer or device by Our Site or Apps when you visit certain parts of Our Site or Apps and/or when you use certain features of Our Site or Apps. This may also incorporate similar technologies such as E-tags HTTP Protocols, JavaScript, Local Storage (including HTML5 and Local Shared Storage) and Beacons. Details of the Cookies used by Our Site or Apps are set out in Part 14 and Our Cookies Policies;

Cookie Law”  means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Consent”  means the consent of the data subject which must be freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify their agreement to the processing of personal data relating to them;

Data Controller”  means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, the Company is the data controller of all personal data relating to any data subject used in Our business for Our commercial purposes;  

Data Processor”  means a natural or legal person or organisation which processes personal data on behalf of a data controller;

Data Protection Legislation”  means the Data Protection Act 1998 and Data Protection Act 2018 together with any other statutory instrument of the UK Parliament.

Data Subject”  means a living, identified, or identifiable natural person about whom we hold personal data;

EEA”  means Western Europe, the European Union, EU member states, or countries in the European Economic Area

UK”  means the jurisdiction of the United Kingdom of Great Britain and Northern Ireland.

 

"Machine Learning Summary" means the information provided on Our Site and Apps titled "Machine Learning" and available at https://legalutopia.co.uk/machine-learning.html;

 

Products and Services” means any product or service provided by the Us as identified on Our Site and Apps.  
 

2. Information About Us

Our Site and Apps are owned and operated by Legal Utopia Limited (referred to as “Our”, “Us”, “We”, “Legal Utopia”), a limited company by shares, registered in England under company number 10909418. Registered address: Level 30, The Leadenhall Building, 122 Leadenhall Street, City of London, EC3V 4AB.

Data Protection Officer: Fraser Matcham.

Email address: fraser@legalutopia.co.uk.  

Postal address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.

Regulation and Compliance Officer: Robert Marcus. 

Email address: robert@legalutopia.co.uk.

Postal address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.

 

 

3. What Does This Policy Cover?

3.1 This Privacy Policy applies only to your use of Our Site and Apps. Our Site and Apps may contain links to other websites, portals, or similar online pages. Please note that We have no control over how your data is collected, stored, or used by other websites, portals, or similar online pages and We advise you to check the privacy policies of any such websites, portals, or similar online pages before providing any data to them.

 

4. What Is Personal Data?

4.1 Personal data is defined by the Data Protection Act 2018 as ‘any information relating to an identified or identifiable living individual’. This includes any person who can be directly or indirectly identified in particular by reference to an identifier’.

4.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

5. What Are My Rights?

5.1 Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

a) The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data updated if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.

d) The right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to Us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i)Rights relating to automated decision-making and profiling. 

5.2 For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

5.3 It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

5.4 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice.

5.5 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioners’ Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.

 

6. What Data Do You Collect and How?

6.1 Depending upon your use of Our Sites and Our Apps, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

6.2 When using Our Sites and Our Apps, you may be required to generate a password to create or access your account to give you access to certain parts of Our Sites and Our Apps, you are solely responsible for keeping your password confidential and safe.

6.3 We do not store credit or debit card information. Payments are processed via a third party payment provider(s) that is fully complaint with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology. 

Data Collected How We Collect Data
Identity Information: including names, titles, dates of birth, and identify documents. We ask everyone that visits Our Sites and Apps to provide some or all of this information when corresponding with Us, responding to a Subject Access Request, completing regulatory checks, or when otherwise engaging with us, including accessing our products and/or services.

We may also use this information to provide or support the provision of Our products and services. This information may be provided by a third party, such as a regulator or government agency.
Contact Information: including email addresses, residential and work addresses, phone numbers, and social media and communication account IDs. We ask everyone that visits Our Sites and Apps to provide some or all of this information when entering into or performing a contract related to our products and/or services, subscribing to Our newsletter or marketing materials, and engaging in correspondence with us.

We may also use this information to provide or support the provision of Our products and services. This information may be provided by a third party, such as a regulator or government agency.
Business Information: including business name, job title, company structure, company number, registered and/or trading address, date of incorporation. We ask everyone that creates an account on Our Apps to provide some or all of this information when entering into or performing a contract related to Our products and/or services, and engaging in corresponding with Us.

We may also use this information to provide or support the provision of Our products and services. This information may be provided by a third party, such as a regulator or government.
Payment Information: including transaction numbers, transaction values, transaction dates and times, and bank details. We ask everyone to provide some or all of this information when entering into or performing a contract related to our products and/or services.
Profile Information: including purchase history, settings preferences, login details. We ask everyone that uses Our Apps to provide some or all of this information when using Our Apps. This is for the purposes of improving your and others’ experience(s) and Our products and services.
Technical Information: including IP addresses, browser type and version, user device type and model, user device operating system, referral pathways, keyword search pathways, network domain, internet service provider, audience demographics, CPU, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters, mobile carrier, IDFA, Android ID, Session ID, User ID, and other user source and engagement data. We ask everyone that visits Our Sites and Apps to provide some or all of this information. This information is for the purposes of improving and securing Our Sites and Apps, as well as carrying out anti-fraud, security monitoring, service diagnostics and market research.
Legal Claims, Proceedings, Problems and Disputes Information: including a description of the issue or dispute, your role and status within such issue or dispute, and the remedy you are seeking. As well as any file, form, or document uploaded or provided on Our Apps in relation to a legal matter, problem, dispute, or concern. We ask everyone that uses Our Apps to provide some or all of this information when engaging with Our products and/or services. This information is collected for the purposes of performing a contract, improving Our Apps, as well as commercial research.
Research Information: including relationship status, job title, gender, income bracket, location, age, and first language. We ask everyone that uses Our Apps to provide some or all of this information when consenting to participate in Our research. This information is collected for the purposes of conducting commercial research only and is entirely voluntary.

7. How Do You Use My Personal Data?

 

7.1 Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do. What Data We Use Our Lawful Basis
Registering you on Our Sites and Apps. Technical Information, Identity Information, Contact Information. Step prior to entering into a contract, Performance of contract, Consent.
Providing and managing your Account. Business Information, Identity Information, Contact Information, Payment Information, Technical Information. Step prior to entering into a contract, Performance of contract, Consent, Compliance with legal obligations.
Providing and managing your access to Our Sites and Apps. Contact Information, Profile Information, Technical Information. Step prior to entering into a contract, Performance of a contract, Consent.
Personalising and tailoring your experience on Our Sites and Apps. Technical Information, Profile Information. Consent.
Administering Our Sites and Apps. Technical Information, Profile Information. Consent, Performance of contract, Legitimate Interest.
Administering our business. Identity Information, Profile Information, Payment Information, Business Information, Contact Information. Consent, Step prior to entering into a contract, Performance of contract, Compliance with legal obligations, Legitimate Interest.
Supplying our products and services to you. Identity Information, Profile Information, Payment Information, Business Information, Contact Information, Legal Claims, Proceedings, Problems and Disputes Information. Performance of contract, Compliance with legal obligations, Consent.
Managing payments for our products and services. Payment Information, Identity Information, Business Information, Contact Information. Performance of Contract, Compliance with legal obligations, Consent.
Personalising, improving and tailoring our products and services for you and others. Technical Information, Profile Information, Legal Claims, Proceedings, Problems and Disputes Information. Performance of Contract, Legitimate Interest, Consent.
Communicating with you. Identity Information, Profile Information, Contact Information, Business Information. Consent, Step prior to entering into contract, Performance of Contract.
Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by contacting Customer Service details in Part 15 or clicking unsubscribe). Identity Information, Profile Information, Contact Information, Business Information. Consent.
Conducting commercial research activities. Research Information, Profile Information, Legal Claims, Proceedings, Problems and Disputes Information, Technical Information. Consent.

7.2 We may use your Legal Claims, Proceedings, Problems and Disputes Information, Profile Information, and Technical Information collected from Our Sites and Apps to help Us improve the use of Our products and services, specifically to make use of Artificial Intelligence Technology to help monitor and improve its performance and build upon its proficiency. We always ensure that no data that can directly identify you or others is included in this process. This data will not be used to make any decision about you or others, it is only used to improve Our products and services delivering a better, more comprehensive service to you and other users of Our products and services. We implement strict confidentiality and data security policies and provisions at all times.  

7.3 With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

 

7.4 Third Parties including, but not limited to, Google LLC, Apple Inc, Amazon Web Services EMEA SARL, Amazon Web Services Inc, AppsFlyer Ltd, Hotjar Ltd, Twitter Inc, LinkedIn Corporation, Facebook Inc, Aut O’Mattic A8C Ireland Ltd, Microsoft Corporation, Reddit Inc and Formspree Inc may use third-party Cookies on Our Site and Apps, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.

7.5 We use an automated system to provide Our recommendations. As it is a recommendation system it is you who takes decisions about your particular legal issue and whether to obtain further advice. Our service provides support for your decisions. Our Machine Learning Summary will help you understand how the system operates and the level of reliance to place on it.

7.6 We  We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 15.

7.7 If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.

7.8 In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

8.1 We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How long we keep it
Identity Information: including names, titles, dates of birth, and identify documents. Duration of Correspondence, Performance of Contract, Compliance with Legal Obligations + a period up to 1-year.
Contact Information: including email addresses, residential and work addresses, phone numbers, and social media and communication accounts IDs. Duration of Correspondence, Performance of Contract, Compliance with Legal Obligations + a period up to 1-year.
Business Information: including business name, job title, company structure, company number, registered and/or trading address, date of incorporation. Duration of Correspondence, Performance of Contract + a period up to 1-year.
Payment Information: including transaction numbers, transaction values, transaction dates and times, and bank details. Duration of Correspondence, Performance of Contract, Compliance with Legal Obligations.
Profile Information: including purchase history, settings preferences, login details, and feedback. Duration of Information + a period up to 3-years.
Technical Information: including IP addresses, browser type and version, user device type, user device operating system, referral pathways, keyword search pathways, network domain, internet service provider, audience demographics, and user source data. A period of up to 3-years.
Legal Claims, Proceedings, Problems and Disputes Information: including a description of the issue or dispute, your role and status within such issue or dispute, and the remedy you are seeking. Duration of Performance, Compliance with Legal Obligations + a period up to 7-years.

9. How and Where Do You Store or Transfer My Personal Data?

 

9.1 We share your data with external third parties, as detailed below in Part 10, that are based outside of the UK and EEA. The following safeguards are applied to such transfers:

9.2 We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

9.3 Please contact Us using the details below in Part 15 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a country outside of the UK.

9.4 The security of your personal data is essential to Us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where We are legally required to do so;

  • Legal Claims, Proceedings, Problems and Disputes Information and Research Information is only shared with Amazon Web Services Inc; and Amazon Web Services EMEA SARL for the purposes specified by Us;

  • Operating data storage systems that conduct automatic software patching, back-ups, systems failure detection, recovery and redundancy back-ups, traffic and access restrictions;  

  • Optimising our storage databases to segregate and encrypt personal data;

  • Operating strict access security requirements to hardware and software which has access or could have access to personal data; 

  • Operating appropriate organisational, anti-virus, hardware, software, and data storage security measures to limit use of and proactively protect personal data breaches.  

 

10. Do You Share My Personal Data?

10.1 We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

10.2 If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

10.3 If We have your consent to do so, We may transfer your personal data outside of the UK or EEA in order to deliver Our Site and Apps to you, as well as any of Our Services.

10.4 In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or a request of a government authority; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms of use or contracts of sale, or threats to the security of Our services or the physical safety of any person. 

10.5 We may sometimes contract with the following third parties to supply certain products and services. Those third-party data processors are bound by strict confidentiality and data security provisions, including (where relevant) a data processing agreement or addendum, and they can only use your data in the ways specified by Us. 

10.6 We may share aggregated data for commercial reporting or research purposes that does not personally identify you, but which shows general trends in the legal marketplace and of Our/others products and services.  

Recipient Activity Carried Out Sector Location
Wix.com Ltd (Data Processor). Our Sites storage, processing, and administration. E-commerce – website design, Internet cloud computing, online services. USA, Europe, Israel, other.
Google LLC; Google Ireland Limited; Google Commerce Limited; Google Payment Corp; Google Asia Pacific Pte (Data Processor). Our Site’s and Apps’ data analytics; Our Apps’ delivery, storage, payments, analytics, processing, services, geo-mapping, and administration. Our business administration, communication, and customer service support. Internet Cloud computing, Computer software, computer hardware, artificial intelligence, advertising, data analytics. USA, Europe, Asia.
Facebook Inc (Data Controller). Our Apps account creation (sing-up) and login administration. Social media advertising. USA
Starling Bank Ltd (Data Processor). Our payments processing, storage, and administration. Banking services. UK, EU, USA
Jurit LLP (Data Processor). Our legal advisors. Legal services. UK
Amazon Web Services Inc (Data Processor). Our Apps delivery, storage, analytics, payments, processing, and administration. E-commerce and cloud computing. E-commerce and cloud computing. USA
Amazon Web Services EMEA SARL (Data Processor). Our Site’s and Apps’ delivery, storage, analytics, payments, processing, and administration. E-commerce and cloud computing. Luxembourg, Ireland, UK
Apple Inc (Data Processor). Our Apps delivery, storage, analytics, payments, processing, and administration. Internet Cloud computing, Computer software, Computer hardware, Online services. USA
Hotjar Ltd (Data Processor) .Our Site’s behavioural analytics provider. Digital behavioural analytics UK, Ireland, USA, EEA
Stripe Inc (Data Controller) A third-party e-commerce payment provider for purchases with Us. Online payments. US
PayPal Inc (Data Controller) A third-party e-commerce payment provider for purchases with Us. Online payments US
The Rocket Science Group LLC A third-party email marketing service provider for Our marketing activities. E-commerce Software marketing Software. UK, USA, EEA
Facebook Ireland Ltd (Data Processor) A third-party providing analytics and marketing services. Automated sign-up and log-in API for Our Site and Apps. Advertising UK & USA
AppsFlyer Inc A third-party providing data attribution and event analytics tracking software for Our Site and Apps. Mobile app analytics. USA, Europe, Israel, other.
FormSpree Inc (Data Processor) A third-party form management platform provider for Our Site of customer correspondence or newsletter subscription. E-commerce solution UK, EEA, USA
Slack Technologies Inc, Slack UK Limited, Slack Technologies Limited (Data Processor) A third-party communications platform provider for internal communications and correspondence. E-commerce communications platform UK, Ireland, USA
Legal Services Providers (Regulated by the Solicitors Regulation Authority Limited) Legal services as instructed by Our customers and clients on Our Apps. Legal Services UK

10.6 If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

10.7 If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9

 

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site and Our Apps, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and, at the point of providing your details and by managing your Account).

 

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

12. Can I Withhold Information?

12.1 You may access certain areas of Our Site and Apps without providing any personal data at all. However, to use all features and functions available on Our Site and Apps you may be required to submit or allow for the collection of certain data.

 

12.2 You may restrict our use of Cookies. For more information, see Part 14.

 

13. How Can I Access My Personal Data?

13.1 If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

13.2 All subject access requests should be made in writing and sent in accordance with Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use in Our App. You do not have to use this form, but it is the easiest way to tell Us everything We need to know to respond to your request as quickly as possible.

13.3 There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

 

13.4 We will respond to your subject access request in less than one calendar month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

14.1 Our Sites and Apps may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and Apps to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

14.2 By using Our Sites and Apps, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Sites and Apps for improving the experience and securing Our Sites and Apps. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Sites and Apps for your use and experience of Our Sites and Apps which may not be impaired by refusing consent to them.

14.3 We have separate Cookies Policies that provide the full details on how We use Cookies and similar technologies to assist Us in Our business, advertising, and marketing decisions, as well as to inform Us on your and others’ use of Our Site and Apps. Our Cookies Policies apply separately to Our Site and Our Apps for ease of reference.

 

​15. How Do I Contact You?

15.1 To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer):

  • Email address: customerservice@legalutopia.co.uk.

  • Postal Address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR. 

  • Subject Access Request via Our App (see ‘Help’ tab).

 

16. Changes to this Privacy Policy

16.1 We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

16.2 Any changes will be immediately posted on Our Sites and Our Apps and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites or Our Apps following the alterations. We recommend that you check this page regularly to keep up-to-date. 

16.3 Any changes to Our use or addition of cookies as referenced in this policy and Our respective Cookies Policies, will only apply on your renewed consent as sought at the relevant time of said change(s).

16.4 This Privacy Policy was last updated on 05th March 2021