MyLaw Privacy Statement MyLaw is committed to respecting your privacy and protecting your personal information. This Privacy Statement sets out what we do with your personal information collected from you when you use our digital platforms including our website and how we keep it secure. It explains what personal information we collect, where, why and how we collect it, as well as what your rights are over the personal information we hold about you. We use the terms "personal data" and "personal information" interchangeably in this Statement to mean details which identify you or could be used to identify you, such as your name and contact details, details of your enquiries including your employment details etc This Privacy Statement gives effect to our commitment to protect your personal information. It applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a service user or potential service user including: when you make an enquiry with us or use our services; when you interact with us on social media or use our websites or mobile applications, through our online Zoom meetings, contact our service agents and/or book to use our services through third parties (such as legal services providers);. The purpose of this Privacy Statement is to enable you to understand how we process your personal data and to exercise control over it. The principle of "transparency" in data protection law requires that we communicate to you (via this Privacy Statement) about how we process your personal data in an easily accessible and easy to understand format. As a valued MyLaw digital visitor or service user, your personal privacy is very important to us. Therefore: We are transparent about the personal data we collect and what we do with it. We use the personal data you give us for the purposes described in this Privacy Statement, (this include providing you with services you have requested / enhancing your experience) We also use your personal data to help us understand you better so that we can improve your guest experience / provide you with relevant offers. If you tell us you don't want to receive marketing emails we will stop sending them. We will, of course, continue to send you essential information relating to a product or service you have purchased to keep you informed about your services. We put in place measures to protect your personal data and keep it secure. We respect your data protection rights and aim to give you control over your personal data. WHO WE ARE For the purpose of the General Data Protection Regulation (“GDPR”), the data controller of this website is My Working Law Limited and our address is 25 Herbert Place, Dublin, D02 AY86. Ireland. Should you have any queries about this Privacy Statement, or wish to exercise your rights as set out in herein, please email us on info@mylaw.ie. Without prejudice to your rights under applicable laws, this Privacy Statement is not contractual and does not form part of your contract with us. This Privacy Statement is applicable to services provided by My Working Law Limited. References to "MyLaw”, “we", "our" "ourselves" and "us" means My Working Law Limited, as applicable. Any reference to MyLaw herein should also be taken as a reference to My Working Law Limited. PRIVACY ESSENTIALS Key information "at a glance". For details please read the Privacy Statement in full. Who is collecting your data? My Working Law Limited is the data controller of your personal data where you book services that we provide to you. The relevant MyLaw panel legal services professional appointed to you will be identified in your booking confirmation and will also separately be a "data controller" of your personal information for the purposes of providing that third party service. You can access the privacy statements of those providers from them directly. What personal data do we collect? We may collect the following data: your name, title, contact information including email address and phone number; employment status and title; information supplied by you via our booking forms; payment details; purchase history; sales channel; social media interactions, information about your searches and web usage, Account login details, information on the queries you have submitted to us. What do we do with the personal data we collect? We require your information to deliver services to you and to understand your needs and provide you with a better service. in order to respond to a query you may have submitted to us through the “Contact Us” or section of our website or via a booking form. From time to time, we may also use your information to contact you for market research purposes. We may use your information to improve our products and services or customize the website/app according to your interests. We may send promotional emails about special offers and deals to the email address you have provided (unless you indicate you don't wish to receive these). To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, survey and training purposes. To improve our website to ensure that content is presented in the most effective manner for you and for your device. To keep our website safe and secure. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA Consent: We process your personal data where you have given your consent to the processing of your data (which you may revoked at any time). Legal Compliance: We use your personal data in order to comply with any legal and regulatory obligations, to enforce our legal rights and to protect the rights of third parties. Legitimate Interests: In most cases, it is in our legitimate interest to process your personal data for the following reasons: To respond to any queries that you have submitted through the website. To allow us to provide the services you request from us. For the administration and operation of our services, as well as for marketing and promoting our firm’s legal services. When we rely on legitimate interests as a legal justification for processing your personal data, we must consider whether those legitimate interests are overridden by your interests, fundamental rights and freedoms. Where we have considered these matters and we believe that our legitimate interests are not overridden by your interests, fundamental rights and freedoms. If this were to change and if we think that there is a risk that one or more of your interests, fundamental rights and freedoms may be affected, then we will not use your personal data unless there is another legal basis for us to do so (for example by obtaining your consent). How do we keep your personal data secure? In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. How can you control your personal data? If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by clicking on the unsubscribe link in each marketing email or via the unsubscribe page. We may use your personal data to send you promotional emails about third parties which we think you may find interesting. We will not sell your personal data to third parties. If you are a "registered user" of our website/app or an you can update your account details on a self- service basis. You may request details of personal data which we hold about you (please see below). If data we hold on you is incorrect/ incomplete, please contact us (details above and below). We will promptly correct any data found to be incorrect. DATA RETENTION We will only retain your personal data for as long as necessary to fulfill the purpose for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. Depending on the nature of the information we hold and the purposes for which it is processed, this will determine the number of years we need to retain your personal data in our system. It is our policy to retain documents in accordance with any retention period required by law or to the end of the period in which litigation might arise from our engagement. How do we use cookies? Cookies help us to keep our website functioning securely and to provide you with a better service. Cookies allow us to recognise your device or computer and to see how you interact with our website, but not to identify you as an individual. You can choose to accept or decline cookies or change your cookie preferences on the website. Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set. MORE DETAILED PRIVACY STATEMENT Any personal information processed by MyLaw in connection with this Privacy Statement is controlled by My Working Law Limited as applicable, which is therefore considered the "data controller" of your personal information under European Union, UK and Irish data protection law. If you have used our services and been connected with a lawyer, then that lawyer will also separately be considered a "data controller" under European Union, UK and Irish data protection law. Any third party provider of services such as a lawyer, financial services provider, business coach will also separately be a "data controller". The applicable booking terms and conditions will identify the third party provider. You can access the privacy statements of those providers from them directly. This Privacy Statement applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a service user or potential service user, including when you make enquiries with us or use our other services, interact with us on social media or use our websites or mobile applications, contact our service agents or call centres, book to use our services through third parties, you should consult the privacy statements of those third parties for further information. Additional privacy statements may apply if you elect to take certain additional services from us - if this is the case you will be notified of this prior to use. We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), when you use our website or mobile applications, interact with us via email or social media or our online "chat" service on our website and mobile applications or use our contact centres. In addition, we may receive personal information about you from third parties, such as: Legal service providers and financial services providers for the purpose of carrying out administrative duties on your behalf Companies that provide customer information (like fraud prevention agencies, marketing and research companies). Companies contracted by you to provide services to you. If you set up or use a "Registered User profile" on our website/app we will also collect data from you as part of your member account or Registered User profile. The "Registered User profile" is an account you can set up on our website or app with some of your personal information pre-populated. When you access and update your Registered User profile you enable us to optimise your time spent on the website or mobile app. Through the use of profile information provided by you as a Registered User, we are able to personalise your website visit or mobile app experience, and/or ensure that we can communicate details of special offers and other information that may interest you. It can also save you time by pre-filling the online booking section with your personal information. When you communicate with us (via email, social media or our online chat service, or via our call centre) we collect the information you provide to assist in your query (for example contact information, booking reference,) and the contents of the relevant communication, which we use to resolve your query as well as for training and monitoring purposes. You may access and update the information which we hold about you as a Registered User of the website/app by logging in and accessing the relevant section in the website or mobile app. Personal information means details which identify you or could be used to identify you, such as your name and contact details and purchase history. It may also include information about how you use our websites and mobile applications. When you use our services you will need to provide us with your personal details, or the details of those individual(s) who will be using our services. More details about what we collect are detailed above. The main purposes for which we use your personal information are: to fulfill and deliver the services you have asked for Example We will need to use your name, title, address, email, contact details, and payment information so that we can process bookings, take payment, To meet certain legal and regulatory requirements which apply to MyLaw as a legal services technology platform as an airline. to provide services tailored to your requirements and to treat you in a more personal way. to carry out analysis and market research Example We will analyse the way in which our sales channels, products and services are being used by Guests so that we can understand how to improve the service we offer and encourage Guests to use the full range of our products and services. to carry out marketing and keep you informed of MyLaw’s products and services Example We may send you information about our products and services by email (or other electronic communication). We may tailor the content of our websites, applications, emails and other communications to ensure they are as relevant to you as possible - including previous purchases including offers and/or services relating to that or a similar offers. To understand your preferences and provide information about offers, such as upgrades (unless you have opted out of receiving marketing emails). If you've searched for services but not booked we may remind you about our services via social media services (e.g. Twitter) based on the services you searched for previously. We may combine/match anonymised customer relationship marketing data with a third party (e.g. Google) so both companies can understand behavioral activities such as knowing other sites visited. to send you status updates and service communications. Example Even if you have opted-out of receiving marketing information from us, we may still send you communications about the services you have booked to use. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using We may also send you communications about the services you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully. to improve our websites, products and services. Example We may monitor the way that you and other Guests use our website so that we can identify ways to improve the website experience. for management and administrative purposes. Example We may use and retain your personal information, including your purchase history, for administrative purposes, which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud detection / screening (including the use of credit reference agency searches and payment card validation checks) and systems testing, maintenance and development. When we collect information directly from you we may ask you if you do not want to receive our marketing communications. If you choose to receive email marketing from MyLaw, we can let you know about special offers etc. You may receive marketing communications from us if you have you made a booking with us (unless you have indicated that you do not wish to receive marketing communications). We will respect your choice as to what communications you wish to receive and how these are sent. We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. This enables us to send you only those offers and deals that we think will be of most interest to you. How can you change what marketing communications you receive and how you receive them? If you decide you would no longer like to be sent marketing communications you can change your mind at any time. The ways to stop being sent marketing communications are described below. Each marketing communication we send by email will also have an "unsubscribe" option which will allow you to stop you receiving further marketing emails. Marketing to Children We do not knowingly send marketing/promotional emails to children under the age of 16. MyLaw will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons MyLaw collected and needs to use your information. Under EU and Irish data protection laws in almost all cases the legal basis will be: because we need to use your information so that we can process your booking, fulfil your service agreement and otherwise perform the contract we have with you; or because it is in MyLaw’s legitimate interests as an airline to use your personal information in order to operate and improve our business as a legal services technology platform; or because MyLaw needs to use your personal information in order to comply with a legal obligation; or to protect the vital interests of you or another person; or because you have consented to MyLaw using your information for a particular purpose. More information on each legal basis is provided below. In the event that processing of your data is subject to any other laws (other than EU and Irish laws) then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent (as defined according to those laws) in all cases. Performance of a contract with you It will be necessary for MyLaw to use your personal information in order to complete a booking you have made with us. For example, we will need to use information such as your contact details and payment information in order to provide you with the meeting you have requested and paid for. Legitimate Interests As a legal services technology platform, MyLaw has a legitimate business interest to use the personal information we collect in order to offer an effective service and carry out our business. Example We will carry out analysis and use data to improve and personalise your experience. When needed for the conduct of legal claims We may send you emails about our latest offers if you have made a booking with us (unless you have opted out of receiving marketing emails). Compliance with legal obligations There are situations where MyLaw is subject to a legal obligation and needs to use your personal information in order to comply with those obligations. Example To fulfil certain regulatory obligations under the Legal Services Regulation Act To protect the vital interest of you or another person There are situations where we may need to use your personal information in order to protect the vital interests of you or another person. Consent Alternatively, we may collect and use your personal information where you have given your specific consent to us doing so. Example We will rely on your consent where you have provided information to us voluntarily in order to request a meeting with a third party. Where the basis of our processing your data is consent, you can withdraw your consent to such processing at any time by contacting info@mylaw.ie We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you book a Zoom with us we will keep the information related to your booking so we can fulfil the specific call you have made and after that we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a service user, we will remove or anonymise information kept for that purpose after 7 years. When we have collected the personal information based on your consent and we have no other legal reason for retaining the information, if you then decide to withdraw your consent, we will delete your information. We may also disclose your personal information with your consent to the following third parties for the purpose described here: Third party independent lawyers and legal service providers for the purposes of securing services on your behalf Third party advisors eg financial services advisors for the purposes of securing and administering services on your behalf Third parties, such as law firms and law courts, in order to enforce or apply any contract with you Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our staff and assets. To third party websites; subject to our Cookie Policy and your cookie preference settings, we may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites. If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision) We do not sell personal information to third parties. What countries will your personal information be sent to? Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and in particular outside the European Economic Area ("EEA"). Transferring your Personal Data outside the EEA The personal data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). You understand and accept that countries outside the EEA may not have laws which provide the same level of protection to your personal data as laws within the EEA. Where we, or our permitted third parties, transfer your personal data outside the EEA, we or they will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. In the case of transfers by us, we may also transfer your personal data where: (i) The transfer is to a county deemed to provide appropriate protection of your personal data by the European Commission; or, (ii) Where you have consented to the transfer Keep your correspondence confidential When you use our services you will be given a booking confirmation. This will appear on the email confirmation. You should keep your booking confirmation and any reference numbers confidential at all times. Under data protection laws in the European Union, the UK and in Ireland, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within 1 month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to two months, but we will let you know if this is the case. We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below. You may access and update the information which we hold about you as a Registered User of the website/app by logging in and accessing the relevant section in the website or mobile app. Your rights include the following: your right of access to your personal information we hold. There are some limited exceptions to this right such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see "Accessing your personal information" below for more details. your right to ask us to stop sending you direct marketing. To change your marketing preference please refer to the section "When will we send you marketing communications?" above. your right to ask us to correct the personal information you have shared with us (the "right of rectification") if that information is inaccurate. You may be able to update much of it yourself through your account (should you be a "registered user" of MyLaw.ie) including personal and contact details. If you spot any inaccuracies that you can't fix yourself, please email the details toinfo@mylaw.ie. We are not able to amend any data that has been created as a result of a transaction with us e.g. flight history. your right to withdraw consent to processing of data where consent is relied upon by us as the basis of processing. Please note that if you withdraw this consent it may mean we will not be able to provide all or parts of the services you have requested from us and in some circumstances you may not be able to cancel your booking or obtain a refund of any charges you have paid. your right to ask for personal information which identifies you to be removed (anonymised) (also known as the "right to be forgotten") without undue delay in certain circumstances, for example: when you withdraw your consent to processing in circumstances where we have collected the personal information based on your consent and we have no other lawful basis to continue to retain the information where you object to the processing and there is no overriding legitimate grounds for us to continue the processing (See point f below); where your personal data has been unlawfully processed. Your right to object to the use of your personal information where the basis of our processing the information is our legitimate interests (unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights). For more information on the basis on which we process your personal information see What is our legal basis for using your personal information? Example If you ask us to delete all your personal information that we process based on consent (e.g. a request for special assistance) we may need to retain certain information that relates to a contract between you and MyLaw because we need it for our own legal and auditing purposes. Please note that in some circumstances if you exercise this right before you avail of our services, it may mean we will not be able to provide all or parts of the services you have requested from us and you will not be able to cancel your booking or obtain a refund of any charges you have paid. Please note while we will endeavor to erase data in circumstances where an individual has exercised this right and we don't need the data anymore some personal data sets are impossible (or infeasible) to edit to remove individual records, e.g. a server backup or a piece of microfiche. your right to object to the processing of your personal information for direct marketing purposes including profiling for the purposes of direct marketing. Please note if you exercise this right in relation to all MyLaw marketing communications we will no longer send you marketing communications however we will still send you communications about the services you have booked to use. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using. In addition, we will also need to retain and process some of your personal information to make sure you are excluded from future marketing communications. your right to object to automated processing which has a legal effect or similarly significant effects. Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. You have certain rights in respect of automated decision making: you can ask not to be subject to a decision which is based solely on automated processing where that decision produces legal effects concerning you (such as the rejection of a claim); or otherwise significantly affects you. In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision. Your right not to be subject to automated decision making does not apply where the decision which is made is: (a)s necessary for entering into or performing a contract with you; (b) authorised by law and there are suitable safeguards for your rights and freedoms; or (c) based on your explicit consent. However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision. A Guest can do this by emailing info@mylaw.ie If you are a MyLaw.ie registered user and wish to retain your membership or registration you may not be able to exercise some of these rights as we need to process your personal information is required to deliver those services to you. Please note: We may need to retain certain elements that relate to a contract between you and MyLaw because we need it for our own legal and auditing purposes In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to previous services or retain any preferences you have previously shared with us. A record of your individual rights request including the personal information you supplied will be retained for up to 3 years. We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint. Accessing your personal information You can view the following information we hold on you on a self-service basis: If you are a "registered user" or “member” of the MyLaw website you can view personal information held within your registered user account by logging into your account. Alternatively if you wish to access other personal information we hold about you or exercise any other rights we recommend that you make your request in by email and include the following information with your request: Your name The email address used for the relevant service / processing (if applicable) Details of your request We need corroborating information to establish your identity. You must also provide: In all cases, a photocopy of your passport or driving licence, so that we can verify your identity proof of address (e.g. utility bill) dated within the last 6 months (if you wish to receive a response in hard copy) if you are applying on behalf of another person then signed authority (in a form satisfactory to MyLaw) from the individual is required Any details which may help us locate the information which is the subject of your request, for example: Dates or correspondence or Zoom Calls Website member login username Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s)). Please send your request to: info@mylaw.ie. If you wish the information to be provided to you in a machine-readable format please indicate that at the time of making your request. If we change this Privacy Statement, we will let you know about the changes by publishing the updated version on MyLaw.ie and our mobile app. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Statement. This Privacy Statement came into effect on 1st January 2019 replacing our previous Privacy Statement. This Privacy Statement applies to all information we process about you in connection with your relationship with us as a guest or potential guest, service user or client. Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Statement. If you have any questions about this policy or you have any concerns about our handling of your information, please send them to the Data Protection Officer. The Data Protection Officer for MyLaw can be contacted at info@mylaw.ie We hope we will be able to resolve any concerns you may have. You have a right to complain to the Data Protection Commissioner in Ireland at: Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois https://www.dataprotection.ie/docs/Contact-us/b/11.htm