REAL LEGAL LIMITED WEBSITE PRIVACY POLICY

INTRODUCTION

Welcome to Real Legal Limited’s privacy notice.

Real Legal Limited respects your privacy and is committed to protecting your personal data. This privacy notice
will inform you as to how we look after your personal data when you visit our website (regardless of where you
visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Real Legal Limited collects and processes your personal
data through your use of this website, including any data you may provide through this website when you
purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we
may provide on specific occasions when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not
intended to override them.

CONTROLLER

Real Legal Limited is the controller and responsible for your personal data (collectively referred to as ”Real Legal
Limited”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy
notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights,
please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Real Legal Limited Name of
data privacy manager: Claire Stewart

Email address: [email protected]

Postal address: Real Legal Limited 7 Grimshaw Street, Burnley BB11 2AS

Telephone number: 0345 646 0501

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 20 December 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status,
title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and
services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform and other
technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our
third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as this data
does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated
Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when
you:
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using
cookies, and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third
parties and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks; and
(c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services
based inside or outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral
Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in
the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to
sending third party direct marketing communications to you via email or text message. You have the right to
withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased
goods or services from us or if you provided us with your details when you entered a competition or registered for
a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Real Legal
Limited for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a
result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or
not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that
we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the original purpose, please contact
us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in
paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the same way as set out in this privacy
notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit
them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data
to those employees, agents, contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you)
for research or statistical purposes in which case we may use this information indefinitely without further notice to
you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data which
include the following (see Glossary)

• access to your personal data.
• correction of your personal data.
• erasure of your personal data.
• processing of your personal data.
• restriction of processing your personal data.
• transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may
refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to
give you the best service/product and the best and most secure experience. We make sure we consider and
balance any potential impact on you (both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for activities where our interests are overridden
by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against any potential impact on you in
respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for
compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies and individuals within Real Legal Limited who are based the United Kingdom and provide IT and
system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

• Service providers including our website provider based in the United Kingdom which provide IT and system
administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who
provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require
reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables
you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you
provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where
there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right to object to processing (see below),
where we may have processed your information unlawfully or where we are required to erase your personal
data to comply with local law.

Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third
party) and there is something about your particular situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information which override your
rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the
data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have
objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this
will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will advise you if this is
the case at the time you withdraw your consent.