PRIVACY POLICY OF SMARTLEGAL BOOKING-SERVICE
01.07.2022
This Privacy Policy sets out the rules for the processing of the personal data of a Customer who uses SmartLegal electronic system for booking legal services.
The terms used in this Policy have the following meanings:
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SmartLegal
SmartLegal OÜ, registry code 16519543, address Harju maakond, Tallinn, Kesklinna linnaosa, Maakri 30, 10145, administrator of SmartLegal booking-Service
SmartLegal Booking-Service
The website through which contracts for the supply of the Service are concluded between the Customer and the Service Providers.
Customer
A person who uses SmartLegal Booking-Service to book a Legal Service or Consulting Service.
Privacy Policy
This Privacy Policy.
Service
Legal consulting, the provision of which can be booked through SmartLegal Booking-Service.
Service Provider
The provider of the Legal Service or consulting service.
General Regulation
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
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ROLE OF SMARTLEGAL IN THE PROCESSING OF PERSONAL DATA
SmartLegal determines the purposes and means of processing the Customer’s personal data when arranging a booking through SmartLegal Booking-Service and is therefore considered the controller of the Customer’s personal data within the meaning of the General Regulation.
SmartLegal is an independent controller of the processing of the Customer’s personal data within the meaning of the General Regulation. SmartLegal is liable for the processing of data that SmartLegal receives from the Customer through SmartLegal Booking-Service.
If it is necessary to process the Customer’s data in order to book the Legal Service.
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PERSONAL DATA COLLECTED
SmartLegal processes the following personal data of the Customer through SmartLegal Booking-Service:
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Identification
data
Given name and surname, personal identification code, residency
Contact information
Telephone number, address, e-mail address
Booking data
Information on the Service Provider, the time of provision of the Service, the place of provision of the Service and the content of the provision of the Service.
Data concerning questions
Data on the Customer’s question, including information on the reason the Customer wants legal advice. The list of data that SmartLegal processes in a specific case depends on each separate case.
Payment information
Information on payment for the Service, information on the existence of a discount code.
Feedback and suggestions
Data related to the feedback or suggestions submitted by the Customer or their parent or guardian, including the booking number in connection with which the suggestion or feedback has been submitted, in relation to the time booked with the Service Provider the suggestion or feedback has been submitted for, in relation to the Service the suggestion or feedback has been submitted for or the name of the worker whose activities the feedback has
been provided on.
Platform information
Data collected by SmartLegal using the cookies of SmartLegal Booking-Service, such as information about the device used to visit the website (model, name, IP address), information about preferences, use of the website.
SmartLegal processes personal data about the Customer, which it receives directly from the Customer. SmartLegal does not collect personal data about the Customer from third parties, except to check the data submitted by the Customer in the general information system.
Disclosure of personal data to SmartLegal is voluntary, but if the Customer decides not to disclose the data, the Customer cannot book the Services for themselves through SmartLegal Booking-Service.
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PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA
3.1 SmartLegal processes the Customer’s personal data only pursuant to applicable law and for the stated purposes.
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Data sets
Purpose
Legal basis
Identification data
To allow the Customer to book the Service with the Service Provider.
Contract for the provision of the Booking Service (GDPR art 6 (1)(b)).
Booking data
To allow the Customer to book the Service with the Service Provider.
Contract for the provision of the Booking Service (GDPR art 6 (1)(b)).
Contact information
To allow the Customer to book the Service with the Service Provider.
To contact the Customer, including transmission of additional guides and instructions related to the Service.
To be transferred to databases and registers in order to fulfill the obligations arising from the legislation in force.
Contract for the provision of the Booking Service (GDPR art 6 (1)(b)).
Contract for the provision of the Booking Service (GDPR art 6 (1)(b)).
Fulfillment of a legal obligation (GDPR art 6 (1)(c)).
Data concerning legal issue
To make sure that the Service can be provided to the Customer.
Fulfillment of a legal obligation (GDPR art 6 (1)(c)).
Payment information
To pay for the Service.
Contract for the provision of the Booking Service (GDPR art 6 (1)(b)).
Feedback
To ensure the quality of the service.
An authorisation granted to ensure the performance of a legal
obligation.
Information from the SmartLegal Booking- Service website
To perform website analytics in order to understand the preference of website users and what features users use on the website.
SmartLegal’s legitimate interest (GDPR art 6 (1)(f)).
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AUTOMATED DECISION OR PROFILING
4.1 SmartLegal may process the Customer’s personal data for automated decision-making and use automated processing of the Customer’s personal data, including profiling and data modeling, to provide services in accordance with the Customer’s preferences, set service prices, detect fraud and fraud risk or meet marketing objectives. The Customer has the right to submit their opinion to SmartLegal and to contest the automatic decisions by sending a corresponding notice to the contact details referred to in clause 9 of this Privacy Policy.
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TRANSMISSION OF PERSONAL DATA
5.1 SmartLegal does not transmit personal data to third parties, unless it is necessary for the performance of the contract concluded with the Customer or to ensure the performance of the contract or if the obligation to transmit such data arises from legislation.
5.2 SmartLegal transmits the Customer’s personal data both to persons who are considered independent controllers in the processing of the Customer’s personal data (i.e. the Service Provider selected by the Customer) and to persons who process the Customer’s personal data under SmartLegal’s authorisation and supervision (e.g. server service providers, payment service provider Maksekeskus AS, IT software developers).
5.3 As the processors, SmartLegal uses only those partners who are committed to processing personal data in accordance with these principles of processing personal data and applicable law.
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RETENTION OF PERSONAL DATA
6.1 SmartLegal does not retain Customer’s personal data longer than is necessary for the purposes of processing personal data or pursuant to applicable law.
6.2 Pursuant to the Accounting Act, we store accounting documents for seven years.
6.3 We generally store the data collected for the conclusion of an agreement with the Customer, the longer retention period of which has not been prescribed by applicable law, as long as they are required for the purposes of the contract during the term of the contract or up to three years after expiry of the contract.
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SECURITY OF PERSONAL DATA
7.1 SmartLegal ensures the security of personal data processing in order to protect personal data against unintentional or unauthorised processing, disclosure or destruction.
7.2 Taking into consideration the latest scientific and technological developments, the cost of implementation and the nature, scope, context and purposes of personal data processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons posed by the processing, SmartLegal, upon processing of personal data, implements appropriate technical and organisational measures for ensuring the security of personal data.
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RIGHTS OF THE CUSTOMER
8.1 Upon processing personal data, the Customer has all the rights of a data subject pursuant to applicable law, in addition to the following rights:
8.1.1 Right of access: The Customer has the right to ask whether SmartLegal has any of their personal data and to obtain information about the Customer’s personal data processed by SmartLegal at any time.
8.1.2 Right to rectification of personal data: The Customer has the right to request that SmartLegal specify or rectify their personal data if they are inadequate, incomplete or incorrect.
8.1.3 Right to object: The Customer has the right to submit objections to the processing of their personal data by SmartLegal if the use of personal data is based on the legitimate interest of SmartLegal.
8.1.4 Right to request erasure of personal data: The Customer has the right to request the erasure of personal data if their personal data is processed with their consent and they have withdrawn their consent.
8.1.5 Right to restriction of processing: The Customer has the right to request that SmartLegal restrict the processing of the Customer’s personal data based on current legislation, e.g. if SmartLegal no longer needs the Customer’s personal data for the purposes of processing or if the Customer has objected to personal data processing.
8.1.6 Right to withdraw consent for processing: If the processing of personal data is based on the Customer’s consent, the Customer may withdraw their consent to SmartLegal at any time.
8.1.7 Right to data portability: The Customer the right to obtain personal data from SmartLegal which they have submitted to SmartLegal and which is processed on the basis of their consent or in order to perform the contract concluded with them, in writing or in a commonly used electronic format, and, if it is technically possible, to request that SmartLegal transmit the data to a third service provider.
8.1.8 Right to file a complaint: To file a complaint with the Data Protection Inspectorate or a court in the case of a violation of the Customer’s rights.
8.2 The Customer’s rights related to the processing of personal data listed in this chapter do not include all of their rights. In certain cases, the rights of other data subjects or the legal obligations of SmartLegal may limit the rights of the data subject.
8.3 In order to exercise the rights associated with the processing of personal data or to submit applications, the Customer must contact SmartLegal (contact information in clause 9).
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CONTACT INFORMATION
9.1 For questions or requests related to the processing of personal data, the Customer must contact SmartLegal or the Data Protection Officer of SmartLegal by e-mail or post. Contact information of SmartLegal:
Business name: SmartLegal OÜ
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Maakri 30, 10145
E-mail: info@smartlegal.ee
Contact information of the Data Protection Officer of SmartLegal: dpo@smartlegal.ee