LawSentry Privacy Policy
Last Updated: 13 January 2023
1. BACKGROUND
1.1. Overview: This privacy policy sets out:
1.1.1. Transparency about how We collect and use Your Personal Information, including when and how it is shared;
1.1.2. Information about how We protect Your Personal Information;
1.1.3. Information about what rights You have in relation to Your Personal Information; and
1.1.4. Information on how We will facilitate Your exercise of such rights and how You can contact Us to clarify any questions or concerns.
Find out more about how We manage Your Personal Information below.
1.2. Agreement: We use Your Personal Information for various purposes as set out herein. By using Our Site and the other Platforms, You agree to the collection and use of information in accordance with this Privacy Policy.
2. PARTIES
2.1. Corporate Details: The Platforms are operated by LawSentry DSG Pte Ltd (UEN 202139881D), a private company incorporated in Singapore with its registered office at 1, North Bridge Road, 08-08 High Street Center, Singapore 179094 (“We”, “Our”, “Us”).
2.2. Sole Obligor: We are the sole obligors in respect of the provisions of the services under Our Terms of Service. None of Our Affiliates have any obligations to You under this Privacy Policy.
2.3. Natural Person: You are the natural person who is presently visiting the Platform in Your own individual capacity and/or on behalf of a Person that You represent, in each case, as a user who has agreed to be bound by this Privacy Policy (“You”, “Your”, “Yours”).
3.DEFINITIONS:
3.1. Defined Terms: In this policy:
3.1.1. The following terms defined in Our Terms of Service shall have the same meanings when used in this Privacy Policy: “Affiliates”; “Applicable Law”; “Content”; “Payment Terms”; “Person”; “Platform”; “Regulatory Reasons”; “Services”; “Terms”; the “Site”; “Third Party” and “Use”.
3.1.2. In addition, the term “Personal Information” refers to any data, information, or combination of data and information that is provided by You to Us, or through Your use of Our Services, that relates to an identifiable individual.
4. WHAT INFORMATION WE COLLECT ABOUT YOU
4.1. Types of Information: We collect the following types of information about You:
4.1.1. profile information that You provide when You access Our Services, for example, Your name and email address (collectively, “Access Data”);
4.1.2. information You provide through any one-on-one interactions with Us through Our Platforms, for example when You report a problem to Us or interact with Our personnel, including any materials or information shared with Us (collectively, “User Data”);
4.1.3. communication, marketing, and other preferences that You set in case when You visit or engage with the Platforms including downloading materials on a particular subject or participating in any survey or a questionnaire that We send You (collectively, “Preference Data”);
4.1.4. details of any transactions or purchases, that You undertake with Us (collectively, “Transaction Data”);
4.1.5. payment information, for example, Your payment card information or bank account details (collectively, “Financial Data”);
4.1.6. information about Your device or connection, for example, Your internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices You use to access Our Services and information We collect through cookies and other data collection technologies (please read Our Cookies Policy for details) (collectively, “Technical Data”); and
4.1.7. information about Your use of or visit to Our Platform, for example, Your clickstream to, through and from Our Platform, documents you viewed, used, or searched for, download or other errors, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page (collectively, “Usage Data”).
4.2. Other Sources: We collect the above information when You provide it to Us or when You use or visit Our Platform. We may also receive information about You from other sources, including:
4.2.1. Our personnel and service providers in connection with Our operations or Services, for example for the delivery of the Services or processing of Your payment;
4.2.2. Our Affiliates that provide Us with support services such as information technology, system administrative, and/or marketing services; and
4.2.3. Our business partners and service providers who provide Us with support services such as technical, payment, delivery services, advertising, analytics, market research, and search information services.
4.3. Non-use of Sensitive Data: We do not collect sensitive data or special category data about You. This includes details about Your race, ethnic origin, politics, religion, health or sexual orientation.
5. HOW WE USE INFORMATION WE COLLECT AND BASIS OF PROCESSING
5.1. Use of Personal Information: We shall use Your Personal Information in accordance with Applicable Law. In certain countries, We have to specifically disclose the basis on which We are processing Personal Information. As an example, the EU General Data Protection Regulation ("GDPR") specifies that a data controller is only allowed to use Your Personal Information if it has a proper reason to do so. This includes sharing it outside of the data controller's organisation.
5.1.1. The reasons for which We may use Your Personal Information include where:
5.1.1.1. We have Your consent;
5.1.1.2. We are fulfilling a contract with You in relation to the delivery of a Service;
5.1.1.3 We are under a legal duty to do so;
5.1.1.4. We have a Legitimate Interest to do so;
5.1.1.5. We provide You with informational material, special offers and other general information about other services and events which We may offer on Our Platform that might be of interest to You or Your business in accordance with and are similar to those that You have already purchased, accessed or enquired about unless You have opted not to receive such information; or
5.1.1.6. You have given Us consent to do so for a specific purpose, for example to publish Your information as part of Our testimonials to promote Our Services.
5.1.2. For the purposes of this Privacy Policy, "Legitimate Interest" means where We believe that processing Your Personal Information is necessary for:
5.1.2.1. processing Your payments;
5.1.2.2. keeping Our records up to date;
5.1.2.3. working out which of Our Services may interest You and telling You about them;
5.1.2.4. developing and improving the Services;
5.1.2.5. defining types of customers for the new Services;
5.1.2.6. seeking Your consent when We need it to contact You;
5.1.2.7. efficiently fulfilling Our legal and/or contractual duties; and/or
5.1.2.8. complying with Applicable Law, for Regulatory Reasons and/or participating in a legal claim/process.
5.1.3. We use Your Personal Information for the following legal and compliance reasons:
5.1.3.1 checking compliance with the Terms and this Privacy Policy;
5.1.3.2. responding to requests from any courts, arbitral authorities or regulators;
5.1.3.3. maintaining Our compliance with Applicable Laws or for Regulatory Reasons;
5.1.3.4. preventing fraud;
5.1.3.5. defence against Third Party claims or allegations; and
5.1.3.6. safeguarding the safety and security of any individual including Our personnel.
5.2. Withdrawal of Consent: If You have given Us consent to use Your personal information for a specific purpose, You have the right to withdraw Your consent at any time by contacting Us (please refer to Paragraph 14 for contact information), but please note this will not affect any use of Your information that has already taken place.
6. HOW WE SHARE INFORMATION WE COLLECT
6.1. General: We may share information with Our Affiliates in order to operate Our Platform and to offer and improve Our Services.
6.2. Third Parties:
6.2.1. We share information with Third Parties that provide support services such as marketing, development of new Services, cloud hosting, maintenance, backup, storage, infrastructure, invoicing, payment processing, and business analytics.
6.2.2.Third Party service providers have access to Your Personal Information only for the purpose of performing their services and in compliance with Applicable Laws. We require these Third Party service providers to maintain the confidentiality and security of all Personal Information that they process on Our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of Your Personal Information.
6.2.3. We take reasonable steps to confirm that all Third Party service providers that We engage process Your Personal Information in the manner that provides at least the same level of protection as is provided under this policy.
6.2.4. If You use any Third Party software in connection with Our Services, for example, any Third Party software that Our Platform integrates with, You might give the Third Party software provider access to Your account and information. Policies and procedures of Third Party software providers are not controlled by Us, and this policy does not cover how Your information is collected or used by Third Party software providers. We encourage You to review the privacy policies of Third Party software providers before You use the Third Party software.
6.2.5. Our Platform may contain links to Third Party websites over which We have no control. If You follow a link to any of these websites or submit information to them, Your information will be governed by their policies. We encourage You to review the privacy policies of Third Party websites before You submit information to them.
6.3. Compliance-related reasons: We may share Your information with government and law enforcement officials to comply with Applicable Laws, Regulatory Reasons or to participate in a legal claim/ process.
6.4. Special considerations in relation to sharing with Third Parties: In relation to sharing with Third Parties including for advertising:
6.4.1. We do not share Your Personal Information with Third Parties for commercial purposes;
6.4.2. in particular, We do not sell Your Personal Information to Third Parties for the purpose of advertising; and
6.4.3. We may share information with business partners and service providers for the purposes of enhancing the Services.
6.5. Internal Purposes: We use Your Personal Information for other internal purposes. As an example, We sometimes hire other organisations or individuals to perform business-related functions for Us such as maintaining databases, processing payments, delivering Our solutions etc.
6.6. Corporate Events: We may use Your Personal Information in connection with actual and imminent corporate events such as:
6.6.1. a corporate sale, merger, dissolution or sale of assets; or
6.6.2. a business restructuring, insolvency or similar event.
6.7. Transfer with Consent: We may transfer Your Personal Information for other purposes with Your consent.
7. HOW WE STORE AND SECURE INFORMATION WE COLLECT
7.1. General: We exercise all reasonable measures to protect the Personal Information that You provide. However, You should be aware that no technology-dependent system, is foolproof. We will store Your Personal Information for as long as We need to reasonably do so for the purpose for which it is collected and/or as long as it is needed to be retained for legal and compliance reasons.
7.2. Host: We use cloud service providers to host the information We collect to enable Us to operate as a global platform.
7.3. Measures to Protect: In order to protect the security and integrity of Your Personal Information, access to Your Personal Information is restricted to Our personnel or service providers on a need-to-know basis, who will only process Your Personal Information on Our instructions and who are subject to a duty of confidentiality.
7.4. Breach Notification: We have put in place procedures to deal with any suspected data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.
7.5. Retention of Personal Information: We only retain Your Personal Information for so long as it is reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, We shall delete or anonymise Your information, or if this is not possible, We will securely store Your Personal Information and isolate it from further use. We periodically review the basis and appropriateness of Our data retention policy.
8. HOW WE TRANSFER INFORMATION INTERNATIONALLY
8.1. General: We may transfer data outside of Your home country and such country may have laws which have generally less robust protections for the protection of personal data as compared to Your home country.
8.2. Safeguarding Transfer of Information: We will exercise all reasonable precautions to protect the transfer of information/data outside of its originating jurisdiction through contractual arrangements, safe harbours and other legal means.
9. RETENTION OF YOUR PERSONAL INFORMATION
9.1. General: We shall retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We shall retain and use Your Personal Information to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your information to comply with Applicable Laws or for Regulatory Reasons), participate in a legal claim/process and enforce Our legal agreements and policies.
9.2. Usage Data: We shall also retain your Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Platform, or We are legally obligated to retain this data for longer time periods.
10. YOUR RIGHTS
10.1. Rights: You have the right to:
10.1.1. be informed of what We do with Your Personal Information;
10.1.2. request a copy of Personal Information We hold about You;
10.1.3. require Us to correct any inaccuracy or error in any Personal Information We hold about You;
10.1.4. request erasure of Your Personal Information (note, however, that We may not always be able to comply with Your request of erasure if the Personal Information is still necessary for the purpose which We originally collected it for, or for record-keeping or legal compliance purposes);
10.1.5. object to or restrict the processing by Us of Your Personal Information (including for marketing purposes);
10.1.6. transfer Your Personal Information by Us to another organisation (data portability);
10.1.7. request to receive some of Your Personal Information in a structured, commonly used, and machine-readable format, and request that we transfer such information to another party; and
10.1.8. withdraw Your consent at any time where We are relying on consent to process Your Personal Information.
10.2. Opt-Out: You may opt out of receiving marketing materials from Us by using the unsubscribe link in Our communications or by contacting Us (please refer to Paragraph 14 for contact information). Please note, however, that even if You opt-out from receiving marketing materials from Us, You will continue to receive notifications or information from Us that are necessary for the use of Our Services.
10.3. Identity Confirmation: As a security measure, We may need specific information from You to help Us confirm Your identity when processing Your privacy requests or when You exercise Your rights.
10.4. Request Fee: Any request under Paragraph 10.1 will normally be addressed free of charge. However, We may charge a reasonable administration fee if Your request is clearly unfounded, repetitive, or excessive.
10.5. Response: We will respond to all legitimate requests within one (1) month. Occasionally, it may take Us longer than a month if Your request is particularly complex or if You have made a number of requests.
11. CHANGES TO THIS POLICY
11.1. Revise or Modify: We may revise or modify this Privacy Policy from time to time including to reflect changes to Our Services or as a result of Regulatory Reasons.
11.2. Deemed Acceptance: If We make any material changes to the Privacy Policy, it shall be effective seven (7) days after notice of any change that is provided to You and may be done by means including, but not limited to, a posting on the Site or via Your email address registered with Us. Any modification We make to the Privacy Policy after such notice will be deemed acceptance of such modifications. If You do not agree with the Privacy Policy, please do not use the Platforms. Please check the Site frequently to view recent changes.
12. POLICY TOWARDS CHILDREN
12.1. Our Services are not directed to individuals under 16. We do not knowingly collect Personal Information from individuals under 16.
12.2. If We become aware that an individual under 16 has provided Us with Personal Information, We will take steps to delete such information.
12.3. Please contact Us if You believe that We have mistakenly or unintentionally collected information from an individual under 16.
13. OTHER IMPORTANT TERMS
13.1. Enforcement: Even if We delay in enforcing this Privacy Policy, We can still enforce it later. If We do not insist immediately that You do anything You are required to do under this Privacy Policy, or if We delay in taking steps against You in respect of Your breaching this Privacy Policy, that will not mean that You do not have to do those things and it will not prevent Us taking steps against You at a later date.
13.2. Language: This Privacy Policy is drawn up in the English language and the English language version of the same shall always prevail over any translation. This Privacy Policy shall be construed, interpreted and administered in English.
14. CONTACT US
14.1. Contact Address: Please contact Us at info@lawsentry.io.
14.2. Complaint: Please contact Us in the first instance if You have any questions or concerns. If You have unresolved concerns, You may have the right to file a complaint with a data protection authority in the country where You live or work or where You consider as the location of infringement of Your rights.
15. COOKIES POLICY
15.1. Meaning: Cookies are small text files that are placed on Your device by a web server when You access Our Platform. We use cookies to identify Your access and monitor usage and web traffic on Our Platform to customise and improve Our Services. In and of themselves, cookies are harmless and serve crucial functions for Our Platform. Cookies can also generally be easily viewed and deleted.
15.2. Use: We use both persistent cookies and session cookies. A persistent cookie stays in Your browser and will be read by Us when You return to the Site or a partner website that uses Our Services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).
15.3. Types of Cookies: We use the following types of cookies:
15.3.1. Strictly necessary cookies – these are cookies that are required for the operation of the Site. They include, for example, cookies that enable You to log into secure areas of the Site;
15.3.2. Analytical/performance cookies – these allow Us to recognise and count the number of visitors and to see how visitors move around Our Site when they are using it. This helps Us to improve the way the Site works, for example, by ensuring that users are easily finding what they are looking for;
15.3.3. Functionality cookies – these are used to recognise You when You return to the Site;
15.3.4. Targeting cookies – these cookies record Your visit to the Site, the pages You have visited, and the links You have followed;
15.3.5. Payment Provider Cookies - Our payment provider uses cookies in order to process Your payment and for anti-fraud purposes; and
15.3.6. Blocking/Disabling Cookies - You can block cookies by activating the setting on Your browser that allows You to refuse the use of all or some cookies. However, if You do so, You may not be able to access all or parts of the Site.