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LEGALSHIELD UK: PRIVACY STATEMENT

 

PPLSI Limited, which trades as “LegalShield UK”, respects your privacy and is committed to protecting your personal data. This Privacy Statement describes how we look after your personal data:

  • when you visit or use our website or any of our software applications (the “Sites”), including opening and using an online user account, regardless of where you visit or use the Sites from; and/or
  • which we otherwise receive or collect from you in the course of our operations and customer services (including using our products and services).

It also describes certain privacy rights and data protection laws that may apply to you.

It is important that you read this Privacy Statement 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 personal data. This Privacy Statement supplements other such notices and is not intended to override them.

DATA CONTROLLERS

For the purposes of data protection under the Data Protection Act 2018, the General Data Protection Regulation and any applicable national implementing laws, regulations, secondary or other legislation (collectively, the “GDPR”), the legal entities responsible for deciding how we hold and use your personal data are LegalShield UK and its parent company, Pre-Paid Legal Services Inc., a company incorporated in Oklahoma, United States (“LegalShield US”), and this means that we are each the “data controller” of any personal information that we collect from you or that you provide to us. In this Privacy Statement, references to “LegalShield”, “we” “us” and “our” refer to PPLSI Limited and Pre-Paid Legal Services Inc. References to “LegalShield UK” refer to PPLSI Limited, and references to “LegalShield US” refer to our parent company, Pre-Paid Legal Services Inc.

To clarify the essence of the arrangement by which LegalShield collects and processes personal data, both legal entities are considered data controllers in their own right. On occasion, for certain processing activities, LegalShield US may act as a data processor for LegalShield UK. There may also be processing activities for which we would be considered joint data controllers in that we may jointly determine the purposes and means by which your personal data is processed by us.

For the purposes of the GDPR, LegalShield US, in its capacity as a data controller, has designated LegalShield UK, Second Floor, 11 Pilgrim Street, London, United Kingdom, EC4V 6RN as its representative in the EU.

Certain of our Service Providers are also data controllers in their own right in respect of your personal data. To understand what we mean by “Service Provider”, please review our terms and conditions, which are available here: https://privacydefence.co.uk/privacydefence-terms-website-use  

DATA PRIVACY MANAGER

LegalShield UK has appointed the following individual as its data privacy manager:

Mike Files,  Pre-Paid Legal Services Inc., One Pre-Paid Way Ada, OK 74820

Email: [email protected]

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

Summary

LegalShield will only collect personal data required to serve the purpose for which it was collected. The type of personal data we collect will depend upon the nature of your relationship with us (e.g., whether you are a customer, prospective customer, job candidate, service provider, service partner or visitor to the Sites or office), the purpose for which the data is required, and our legal and regulatory obligations.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

LegalShield will collect your personal data in a number of ways, including when you contact us or register with us through the Sites, or by telephone, post, or e-mail.

Further information

Customers

As a customer of ours, the information we collect from you may include the following:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • contact details for other individuals entitled to use the product(s) you have purchased and your relationship to those individuals (if applicable);
  • your date of birth and the dates of birth of other individuals entitled to use the product(s) you have purchased (if applicable);
  • a copy of your driver’s licence, passport, or other suitable documentation to identify you and other individual covered by the product(s) you have purchased from us;
  • your credit card or debit card details if you make a purchase or pay subscription/membership fees for a product or products;
  • your username and password for your online membership account with LegalShield UK;
  • if you choose to use a social media single sign-on service, such as Facebook Connect, we’ll use information from your social media account such as your name and email address and other information from your public profile to authenticate you;
  • information about the product(s) you are purchasing from us and your use of the product(s);
  • any information you send to us, including information relating to the matters about which you contact the Service Providers; and
  • information as required by regulatory “know your client,” anti-money laundering or proceeds of crime legislation - some of this information we may request or obtain from third-party sources.

Prospective customers

As a prospective customer for LegalShield UK, the information we collect from you may include the following:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • information about the product(s) and services you wish to purchase from us.

Third parties

In connection with the provision of our products and services, we collect and process different personal data depending on the products and services being provided, and the third parties with whom we communicate, obtain data from or otherwise deal with in connection with the products being purchased or services provided to our customers.

Prospective employees

As a prospective employee looking to join LegalShield UK, the information we collect from you for recruitment purposes may include the following:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs in order to undertake equal opportunity monitoring and reporting in the public interest;
  • information regarding your criminal and disciplinary records (if any), including from background checking authorities, agencies and any regulators, to carry out our legal and regulatory obligations;
  • details of your references;
  • information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
  • information regarding your academic and professional qualifications;
  • your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
  • a copy of your driver’s licence or other suitable documentation to identify you and verify your identity;
  • information we may request and/or obtain from third-party sources on disciplinary records.

Service Providers

We collect limited information that could be considered personal data from providers of services (including our Service Providers) to LegalShield. The information we collect from you may include the following:

  • your name and contact details (i.e., address, landline and mobile phone numbers, email address);
  • your qualifications and employment history;
  • bank account details, should we need to transfer funds to you.

Users of the Sites

As a user of the Sites or any other website or web address operated by or on behalf of LegalShield UK that links to this Privacy Statement, we collect information that you submit to us when you interact with features of the Sites such as logging into your account and subscribing for news alerts. When you do this we may collect:

  • your name and contact details (i.e., address, home and mobile phone numbers, email address);
  • your username and password;
  • your credit/debit card details for payment purposes;
  • anything you download from the Sites;
  • any information that you input into the Sites.

In addition to collecting information, we collect analytics relating to your time spent on the Sites. We collect the following information:

  • your 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 the Sites.

More information can be found within our Cookies Policy.

Children

Our Sites are not intended for children and we do not knowingly collect data relating to children via the Sites.

Monitoring and Recording Communications

If you contact LegalShield by telephone, including contacting a call centre operated by one of our service providers in relation to the provision of our customer services to you, then your telephone conversation may be recorded. LegalShield records incoming and outgoing telephone calls from its customer services teams for the following purposes:

(a) To establish the existence of facts relevant to its activities; for example, to keep a record of information given via telephone by, or to, customers where it is necessary or desirable for LegalShield to record the information provided during that conversation;

(b) To ascertain compliance with regulatory or self-regulatory practices or procedures relevant to LegalShield; for example, to ensure that we are complying with our own policies and procedures and with applicable laws;

(c) To ascertain or demonstrate standards that are, or ought to be, achieved by our personnel; for example, for quality control and staff training; and

(d) To prevent or detect crime; for example, to monitor for or to detect evidence of fraud or corruption.

LegalShield determines the nature and extent of call recording appropriate for the above purposes taking into account:

(a) The importance that we attach to the sensitive and responsive handling of all calls with our customers and the need for rigorous quality control and staff training to achieve this;

(b) The importance that we attaches to identifying, remedying and addressing the root cause of any calls which are not regarded as a good experience by our customers, recognising that such calls are likely to be isolated occurrences;

(c) The results of any data protection impact assessment in relation to call recording; and

(d) The advice of our data privacy manager.

We use all reasonable efforts to ensure that callers are aware of the recording of telephone calls. We treat a caller’s election to proceed with a call following the playing of a pre-recorded message notifying them of call recording as that person’s consent to the recording of such calls in accordance with the notification provided.

LegalShield does not make call recordings available to any third parties, unless legally obliged to do so. We will not retain telephone recordings for any longer than necessary for the purposes for which they are collected or as required by our data retention policy or other legal requirement, whichever is longer.

LegalShield has determined that it has a legitimate interest in recording telephone calls in accordance with this policy and that the importance which it attaches to such call recording as described in this policy for the purposes set out in this policy are not overridden by the privacy rights of the relevant data subjects.

Visitors to our premises

As a visitor to LegalShield UK’s premises, we may capture the following information about you:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • images captured by our premises’ CCTV cameras.

WHY DO WE COLLECT PERSONAL DATA FROM YOU?

Summary

LegalShield collects and processes your personal data in connection with its business and to pursue our related legitimate interests and rights, including the promotion and marketing of our products and services.

The personal data we collect is processed in compliance with relevant data protection laws and regulations.

Further information

Purpose and legal basis for processing

When processing your personal data, the purpose and legal basis include the following, to the extent that they apply to you:

  • to perform customer services to fulfil our contractual obligations toward you, and on the basis of our legitimate interests, or our customers’ legitimate interests, including to provide the best customer service we can;
  • to support our business processes including our information technology, electronic communications and electronic documents storage, management and transmissions, to fulfil our contractual obligations toward you, or, if not applicable, on the basis of our legitimate interests to provide the best customer service we can, to support our business operations, administration, IT services, and network security, and to prevent fraud;
  • to safeguard your personal data and our IT system with appropriate security, on the basis of your and our legitimate interest in the provision of such security;
  • to exchange information, conduct due diligence, and answer your initial questions, to take steps required to enter into a contract with you, or for the purposes of our legitimate interests to protect our legal rights and a third party’s rights, or, if not applicable, on the basis of your consent;
  • for our recruitment purposes, including in the context of a selection and recruitment procedure, to take steps prior to entering into an employment relationship or contract with you or on the basis that it is our legitimate interest to use your personal data in such a way to ensure that we can make the best recruitment decisions — we will not process any special categories of personal data except where we are able to do so under applicable legislation or with your explicit consent;
  • to keep you up-to-date with news that may be of interest to you, on the basis of our legitimate interests to use your personal data for marketing purposes;
  • to present the Sites and its content in the best possible way for you and on your computer, on the basis of our legitimate interests to keep the Sites updated and relevant, to develop our outreach and business operations, and to develop marketing strategy;
  • for business transactions such as a merger, acquisition by another company, or sale of all or a portion of our assets on the basis of our legitimate interests to sell or expand our business operations; and/or
  • to comply with legal and regulatory requirements applicable to us (including the need to prevent and combat money laundering).

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Where the processing of your personal data is based on your consent only, you have the right to withdraw this consent at any time. We will then erase your personal data and stop processing it.

Marketing

You may receive marketing communications from us if you are an existing customer or if you provided us with your consent or where we are pursuing a legitimate interest and have a lawful right to do so and, in each case, you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting [email protected] at any time.

HOW LONG DO WE KEEP YOUR DATA?

Summary

Your personal data is kept for the time required to pursue the purposes for which it was collected and processed, including for the purpose of satisfying any applicable legal, professional, contractual, regulatory, accounting or reporting requirements.

If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

More information

We will retain your personal data only for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, legitimate administrative or operational purposes, and any reporting requirements. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, the purposes for which we originally collected the personal data, the lawful grounds on which we based our processing, the types of personal data we have collected, and your expectations and requirements. When it is no longer necessary to retain your personal data, we will securely delete or, in some circumstances, anonymize 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 statement to you.

SHARING YOUR PERSONAL DATA

Summary

We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you, or where we have another legitimate interest in doing so. To provide our products and services and effectively run our business, we need to transfer and share your personal data. Transfer and sharing of personal data will occur to:

  • our Service Providers as necessary for us to provide our services and for our Service Providers to provide you with their services,
  • other third party service providers we retain or LegalShield US retains, such as vendors and suppliers;
  • LegalShield US (LegalShield UK’s parent company in the United States), or
  • to public and regulatory bodies in the event we are required to do so.

Some of these transfers will involve international transfers of your personal data outside the European Economic Area (EEA) including to our data centres or to those of our service partners or public and regulatory bodies.

More information

Categories of recipients

Your personal data may be transferred to the following categories of recipients:

  • our Service Providers and their third party service providers;
  • other vendors, suppliers or other third parties we or LegalShield US retain in connection with the provision of our products and services as required to obtain the services we need to operate our business or to provide products and services to our customers;
  • LegalShield US (LegalShield UK’s parent company in the United States); and
  • public authorities if we are required to do so by law or legal process, in response to a request from government authorities, or if we believe disclosure is necessary to prevent personal harm or financial loss.

We reserve the right to transfer your personal data in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will require that the transferee use personal data you have provided in a manner consistent with this Privacy Statement and the applicable legal framework.

International transfers of your personal data

LegalShield UK and LegalShield US share infrastructure, personnel and providers of services in connection with the services we provide and marketing activities that we undertake. LegalShield US also provides customer and support services to LegalShield UK. As a result, LegalShield US will receive or have access to and process your personal data.

Our third party service providers may be based outside the EEA so their processing of your personal data may involve a transfer of your personal data outside the EEA.

Our Service Providers may use third party service providers outside the EEA, and their processing of your personal data may involve a transfer of your personal data outside the EEA.

Whenever we transfer your personal data out of the EEA, where required by law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may either use the above contracts approved by the European Commission or we may transfer data to them if they are part of the EU–U.S. Privacy Shield which requires them to provide similar protection to personal data shared with providers in the European Union.

Where our Service Providers use third party service providers outside the EEA, we require them (and they are required by law) to implement appropriate safeguards with those third party service providers to ensure that your personal data is afforded a similar level of protection as it would be afforded in the EU.

Please contact us if you want further information on the specific mechanisms we use when transferring your relevant personal data out of the EEA.

WHAT RIGHTS DO I HAVE IN RELATION TO MY PERSONAL DATA?

Summary

Depending on the facts and circumstances related to the personal data we collect or obtain about you – including, for example, the nature of the information we process or where you are located or reside – you may have rights regarding the personal data we hold about you afforded under relevant data protection laws. These may include the right to request information about, or access to, the personal data we hold, and rights to complain about how we handle your personal data. LegalShield is committed to honouring rights you have been afforded under data protection laws while ensuring that such rights are exercised in accordance with our other legal and ethical obligations.

More information

Right to request

Under certain conditions, you may have the right to request from LegalShield, among other things:

  • access to certain information concerning your personal data and the way we are processing it;
  • rectification of inaccurate or incorrect personal data;
  • erasure or restriction of inaccurate, incorrect personal data or personal data unlawfully processed;
  • to stop certain processing, at any time, on grounds relating to your particular situation, including profiling, and to stop any processing, at any time, where it relates to direct marketing;
  • to receive your personal data in a structured, commonly used and machine-readable format, enabling you to transmit the personal data to another data controller.

For more information on the full extent of your rights or to exercise your rights, please contact our data privacy manager by mail or e-mail at the addresses indicated above with a brief explanation of your request. When exercising any of those rights, please let us:

  • have enough information to identify you;
  • have proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
  • know the information to which your request relates.

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 for further information in relation to your request to speed up our response.

If you would like to unsubscribe from any email publication you can also click on the ‘unsubscribe’ button at the bottom of the relevant email publication. It may take up to 10 days for this to take place.

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.

Right to complain

We hope that we can resolve any query or concern you raise about our use of your personal data. However, if you believe your personal data is unlawfully processed by LegalShield UK under applicable data protection laws, you may lodge a complaint with the Information Commissioner’s Office (the UK’s supervisory authority for data protection): https://ico.org.uk

How do you protect my personal data?

Summary

Security measures

We place great importance on the security of all personal data. LegalShield has implemented appropriate technical and organisational methods to protect the personal data we hold from loss, misuse, or unauthorised access.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. The Sites are designed to secure the personal data you provide on computer servers in a controlled, secure environment. When personal data (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption.

What if I do not want to provide my personal data?

For customers, prospective customers, candidates, and providers, it is in your discretion to provide personal data to us. However, for us to enter into a contract with you, or other professional, employment or business relationship with you, we will need to obtain certain information, including personal data that may be necessary or legally required. If you do not provide us with all or some of the personal data we request, we may be prevented from entering into a contract with you, providing you with services, or sending you marketing information or other communications that you have requested.

For users of the Sites, providing your personal data is purely voluntarily. Not providing such data may only prevent you from receiving information from LegalShield. Analytical information captured when you use our products or services, access your account and/or visit the Sites is described in our Cookies Policy, which you can review here https://privacydefence.co.uk/privacydefence-cookie-policy.

Amendments to this Privacy Statement

LegalShield may update this Privacy Statement from time to time, and we reserve the right to do so to comply with applicable data protection laws. The effective date of this Privacy Statement is noted at the top of this page. We encourage you to review this page periodically. If we make material changes to the way that we collect, use or share personal data that you have provided, we will post the revised Privacy Statement on the Sites.