Last updated: 19 July 2023
1. Introduction
We are Kartoa Technologies Ltd, registered in England and Wales with company number 13631421 and registered address at 2nd Floor, Howard House, St Johns Walk, Bedford, England, MK42 0DJ. Any reference to “Wooqlaw” or “us” is a reference to Kartoa Technologies Ltd. To contact us, please email us at help@wooqlaw.com. We provide an online platform available at www.wooqlaw.com as well as through the associated mobile apps (the “Platform”). Through the Platform we enable users or clients (“Clients” or “you”) to search for and connect with qualified legal practitioners, and to submit enquiries to individual lawyers or law firms.
Welcome to our Privacy Policy. Wooqlaw respects your privacy and is committed to protecting your personal data. This privacy policy sets out the types of personal information we collect about you when you use our services, how we use and store your personal information, who we share the personal information with, and tell you about the rights and you may have in respect of that personal information.
If you use our services as part of an entity or organisation that has an agreement with Wooqlaw (such as your employer), the terms of that organisations contract for your use of our services may restrict our collection or use of your personal information further to what is described in this policy.
Our services are not intended for children, and we do not knowingly collect data relating to children.
Wooqlaw is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please email our DPO, Zahid Mahmood, at zahid.mahmood@kartoa.com.
You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK regulator 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.
We keep our privacy policy under regular review. This version was last updated on the date shown at its beginning.
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.
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 as 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 our Platform.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Profile DataUsage Data includes information about how you use our Platform, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data includes your current location disclosed by GPS technology.
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 with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
Data about others
If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
3. How we collect your personal data
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 sign up for our services, create an account on our Platform, sign up for our subscription, request our marketing to be sent to you, enter a competition, promotion or survey, or give us feedback or contact us.
Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies server logs and other similar technologies. Please see our Cookie Policy [LINK] for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
We may also collect information about you indirectly, including from:
Business partners, vendors, suppliers, and subcontractors who perform services on our behalf (these companies are authorized to use your personal information only as necessary to provide these services to us);
Analytics and search engine providers that assist us in the improvement and optimization of our Platform;
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
Payment processors for the purpose of fulfilling relevant payment transactions;
Identity and Contact Data from data brokers or aggregators; and
Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
for the performance of our contract with you or to take steps at your request before entering into a contract;
to comply with our legal and regulatory obligations;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before 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.
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 explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules set out in this section, where this is required or permitted by law.
We will use your personal information for the following purposes and on the following grounds:
a. On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
b. On the basis of our legal obligations, we process your personal information when it is necessary:
for compliance with tax, accounting, anti-money laundering and other applicable law and obligations which we are subject to;
for managing your statutory rights;
for notifying you about changes to our terms or privacy policy; and
for ensuring security of your personal data by preventing unauthorised access to it;
c. On the basis of our legitimate interest, we will use your personal information for:
allowing effective performance of our business by ensuring necessary internal administrative, commercial, and security processes (including in finance, controlling, business intelligence, legal & compliance, information security);
verifying your identity, assessing your creditworthiness, and preventing and detecting fraud against you or us;
collecting and recovering money you owed to us;
asking you to provide feedback, leave a review or take a survey;
sending you information about and enabling you to participate in events (including online events) organised by us (with or without another party), including seminars and training; leisure, sports and/or charity events; prize draws and competitions; and surveys, marketing campaigns, market analysis or other promotional activities;
communicating with you and keeping you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information), events and initiatives;
promoting (including by delivering advertisements) and making suggestions and recommendations to you (including by email or when you visit our Platform) about services that may be of interest to you, as well as to personalise content you see on our Platform, and measuring and analysing the effectiveness of the promotions and suggestions we serve you;
using statistical data analytics about your use of our Platform, services to improve the Platform, our services, marketing, customer relationships and experiences;
preventing unauthorised access and modifications to systems;
carrying out and dealing with security-related tasks, such as troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data; and
establishing, exercising and/or defending our legal rights.
5. Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or information about new products and/or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will not sell your personal information to or share it with other organisations for marketing purposes, except where we remain the controller of your personal information and share it with third parties who act as a data processor on our behalf and only process the personal information on our instructions and for the purposes set out above.
You have the right to opt out of receiving promotional communications at any time by:
contacting us at help@wooqlaw.com;
using the unsubscribe link in emails or STOP number in texts; or
updating your marketing preferences in your user profile on our Platform.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Our Platform may also include social media features, such as Facebook Like button and widgets such as the Share button. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted on our site or by a third party, and your interactions with these features are governed by the privacy policy of the company providing it.
Who we share your personal data with
We routinely share personal information with service providers we use to help deliver our services to you, such as security providers and payment service providers. We may also share your personal information with service providers whom we instruct to assist you with the obtaining of legal services such as lawyers, law firms and other professional advisors. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may also share personal information with:
credit reference agencies who may, for example, supply anti-fraud and credit-insight information to us;
social media companies and our advertising partners. For example, we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms;
legal and regulatory authorities including courts or public authorities who may compel disclosure, such as the Solicitors Regulation Authority (SRA), HMRC, Health & Safety Executive and National Crime Agency (NCA) in the event that we are required to make a disclosure under various legislation and regulation or where we have a legal, regulatory or professional obligation to do so or are required to protect the safety or rights of our clients, staff or others;
our professional advisors such as our lawyers or auditors when they need to give us their professional advice;
public authorities, agencies and other government bodies. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
potential corporate buyer. We may also share some personal information in the case of transfer of some or all of our business, during re-structuring or change of ownership of the business. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations;
our insurers or brokers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations; and
our banks. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Your personal information may be held at our offices, third party agencies, service providers, representatives and agents as described above. Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see Section 7 below.
7. International Transfers
We do not generally transfer your personal information abroad.
If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the United Kingdom, then some additional safeguards will apply.
Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.
This means that when we transfer your personal information outside the UK we will only do so where (i) Binding Corporate Rules adopted under applicable data protection laws apply; or (ii) the country where are making the transfer to is a country deemed by the Information Commissioners Office to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have entered into an international data transfer agreement with the service provider containing protections for your personal information.
Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the UK.
8. 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.
Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
We cannot guarantee the security of your personal information transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
9. How long we will keep your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data.
In some circumstances we will 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.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:
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 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:
If you want us to establish the datas accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
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.
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.
You can exercise these rights by sending an email to us at help@wooqlaw.com.
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.