Response to the event of the United Kingdom exiting from the European Union.
Legal Utopia Limited continues to assess its data compliance status in relation to its obligations under this policy and the relevant data protection laws. As it is increasingly likely that the UK will leave the EU without an agreement, we will seek to implement the following upon the date the UK leaves the EU:
2. Legal Utopia Limited will regard any personal data it collects, handles or stores from the EEA to its servers in the UK to be classed or regarded as an international transfer of personal data. As it is unclear whether the UK will be considered a “non-adequate country” in accordance with the GDPR the following provisions applies to enable the continued provision of Our Sites and Our Apps:
i. Where a reference or statement of the territorial scope which includes the UK with respect to Western Europe, the European Union, EU member states, or countries in the European Economic Area (EEA). Until further notice, Legal Utopia Limited continues to incorporate and shall continue to include the UK in all the abovementioned territorial terms.
ii. In accordance with paragraph 3 below, you are consenting to the international transfer of your personal data from those territories abovementioned into the United Kingdom.
3. By continuing to use Our Sites and/or Our Apps on the date the UK leaving the European Union and thereafter, you are accepting the express changes abovementioned. This will continue across all our contractual relationships with Legal Utopia Limited until further notice.
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 websites, legalutopia.co.uk; legalutopia.services; legalutopia.app; legalinnovationzone.co.uk; finservdivergence.co.uk; and legalcrowd.fund (collectively “Our Sites”) and everyone who accesses our mobile applications available from the Apple UK 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.
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 Sites or Our Apps;
"Artificial Intelligence Technology" means such advanced technologies known to use solely computational techniques and processing to emulate cognitive processes off 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 Sites or Our Apps when you visit certain parts of Our Sites or Our Apps and/or when you use certain features of Our Sites or Our Apps. Details of the Cookies used by Our Sites or Our Apps are set out in Part 14, below;
“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 Subject” means a living, identified, or identifiable natural person about whom we hold personal data;
"Machine Learning Summary" means the information provided in Our Apps titled "Machine Learning" and available at legalutopia.co.uk/machinelearning;
“Products and Services” means any product or service provided by the us as identified on Our Sites and Our Apps.
2. Information About Us
Our Sites and Our 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 1LR.
Main trading address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.
Data Protection Officer: Fraser Matcham.
Email address: email@example.com.
Postal address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.
Regulation and Compliance Officer: Robert Marcus.
Email address: firstname.lastname@example.org.
Postal address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.
We are registered with the Information Commissioners’ Office under reference number ZA324233.
You can search the public register of data controllers here: https://ico.org.uk/about-the-ico/what-we-do/register-of-fee-payers/
You can make a complaint to the Information Commissioners’ Officer here: https://ico.org.uk/make-a-complaint/
You can use our template to make a Subject Access Request here: https://www.legalutopia.co.uk/legal
You can access a support page on our use of Machine Learning technologies here: https://legalutopia.co.uk/machine-learning
3. What Does This Policy Cover?
4. What Is Personal Data?
4.1 Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable 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:
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 rectified 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 be forgotten, i.e. 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?
6.2 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.
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:
7.2 We may use your Legal Claims, Proceedings, Problems and Disputes Information, feedback data, and the data concerning your interaction(s) with Our Sites and Our 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; Wix.com Ltd; Amazon Web Services EMEA SARL; Amazon Web Services Inc.) whose content appears on Our Sites and Our Apps may use third-party Cookies, 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 will only use your personal data for the purpose(s) for which it was originally collected unless wereasonably 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):
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 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 Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
9.4 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 third country.
9.5 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 Commissioners’ 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 only;
Operating data storage systems that conduct automatic software patching, back-ups, systems failure detection, recovery, 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.
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.
10.4 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, and they can only use your data in the ways specified by us.
10.5 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.
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 Sites 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 Sites and Our Apps without providing any personal data at all. However, to use all features and functions available on Our Sites and Our Apps you may be required to submit or allow for the collection of certain data.
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 to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use here: https://www.legalutopia.co.uk/legal. 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.
14.2 By using Our Sites, 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 for improving the experience, securing Our Sites. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.
14.3 All Cookies used by and on Our Sites are used in accordance with current Cookie Law.
14.4 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
14.5 Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Sites may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
14.6 The following third-party Cookies may be placed on your computer or device:
14.7 Our Sites and Our Apps uses analytics services provided by Google Universal Analytics (Google LLC); Wix.com Ltd; Apple Inc; Amazon Web Services Inc; Amazon Web Services EMEA SARL, Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Sites and Our Apps are used. This, in turn, enables us to improve Our Sites and Our Apps, including the products and services offered through them.
14.8 The analytics service(s) used by Our Sites use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Sites and Our Apps, it does enable us to continually improve Our Sites and Our Apps, making it a better and more useful experience for you.
14.9 The analytics service(s) used by Our Sites and Our Apps use(s) the following Cookies:
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 Fraser Matcham):
Email address: email@example.com.
Postal Address: Level 30, The LeadenHall Building, 122 Leadenhall Street, City of London, EC3V 1LR.
Subject Access Request: https://www.legalutopia.co.uk/legal
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.