Privacy Notice

Welcome to LawFairy Limited's Privacy Notice.

This Privacy Notice provides information on the types of personal data we may collect about you. It also explains how we will use, store and handle that data and keep it safe. We want you to be fully informed about your rights, and how we use your data.

Important information and who we are

LawFairy Limited ("LawFairy") is the primary data controller and is responsible for your personal data across all platform activities.

LawFairy Services Limited (SRA No. 8011537, Company No. 16218972) is a joint controller with LawFairy Limited only for immigration-related processing. LawFairy Services Limited is the SRA-regulated law firm entity that stands behind the FairyLogic immigration analysis. It may access personal data for the purposes of supervising legal output, handling complaints, and responding to regulatory queries. LawFairy Services Limited is not involved in non-immigration platform activities (such as HR/recruitment, housing tools, or general platform operations).

If you have any questions about this Privacy Notice or our data protection practices, please contact the Data Protection Professional.

CONTACT DETAILS

The Data Protection Professional

LawFairy Limited / LawFairy Services Limited

Email address: info@lawfairy.com

Postal address: 180 The Strand, Level 2, Temple, London, WC2R 1EA

Changes to the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review and from time to time we make changes to it. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will notify you of these changes. We will always display clearly when the Privacy Notice was last amended on the website. At the bottom of the current Privacy Notice on our website, there will be a link to old privacy notices.

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 policy of every website you visit.

The data we collect about you

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

In making use of the products and services that LawFairy offers we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data which includes first name, previous names, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data which includes where you are or have been staying, email address and telephone numbers.
Financial Data which includes information about your mortgage or tenancy or how affordable your mortgage or rental payments are in light of your specific circumstances.
Transaction Data which includes details about products and services you have used LawFairy for.
Technical Data which includes internet protocol (IP) address, your login data, device type, 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 which includes your username and password, actual usage of LawFairy products and services made by you and any feedback.
Usage Data which includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Housing and Immigration Platform Data which includes information provided when using tools that help assess eligibility for housing, immigration, citizenship or other pathways, such as nationality, relationship status, and other relevant details.
HR Platform Data which includes information provided when preparing or submitting job-application materials, such as CVs, job questionnaire responses, and right-to-work information.

We also collect, use and share Aggregated Data such as statistical data which we may use for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific product or service. 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.

In addition to the personal data outlined above, we may collect and process sensitive personal data, which includes:

Health data, which may include information provided during job applications or housing/immigration assessments.
Criminal convictions and offences, when relevant to job applications or eligibility for housing or citizenship.

Sensitive personal data is collected only with explicit consent, in accordance with Article 9(2)(a) of the UK GDPR. Where you use the Platform directly, you provide this consent when you accept our Terms of Business (a separate, clearly identified consent is presented alongside the general terms acceptance). Where your data is submitted by an employer, sponsor, or legal adviser on your behalf, they are contractually required under our Terms of Business (clauses 6.4 and 22.3) to have obtained your explicit consent before doing so.

With your consent, we may also collect the specific location of your device.

We may also collect information from cookies and similar technologies placed on your device and store other cookies and technologies. Please see our Cookies Notice for more information about our use of cookies and similar technologies and how to change your cookie preferences.

How we collect your data

We use different methods to collect data from and about you including:

Direct interactions. You may give us your Identity, Contact and Financial Data or Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

produce documents automated by LawFairy;
create an account on our website or when we create an account for you using information you have provided;
request marketing to be sent to you;
participate in a survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, 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 Cookies Notice for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

analytics providers such as Google based inside OR outside the UK;

and

cyber security professionals based inside OR outside the UK.

When you download products in document format from our website, we will collect the following information from your device: unique identifier (UDID), MAC address or other applicable device identifier and location.

How we use your personal data & the legal bases for those uses

We will only use your personal data when we have a legal basis to do so, including for the following purposes:

To register you as a new user.
To provide you with our products and services.
To manage your relationship with us, including asking you to leave a review or take a survey.
To administer and protect our business and this website, products/services, or user relationships. (including troubleshooting, data analysis, testing, system maintenance, cyber security, support, reporting and hosting of data).
To recommend products or services which may be of interest to you, including sending you marketing emails about them.
To provide eligibility guidance for housing, immigration, citizenship and other pathways. This is an advisory service only and does not determine your legal rights. The assessment may involve processing special category data (such as health information) or data relating to criminal convictions and offences where relevant to the eligibility criteria. All outputs are informational and do not constitute a binding determination of your entitlements.
To facilitate job applications and recruitment. This includes enabling employers to post roles on the platform, matching candidates with suitable opportunities, and processing CVs, job questionnaire responses, and supporting documents you provide. The platform does not make hiring decisions — those are made by the prospective employer. Health data or data relating to criminal convictions is processed only where it is applicable to the role or required by law.
To comply with legal and regulatory requirements, including obligations under the Solicitors Regulation Authority rules applicable to LawFairy Services Limited.
To meet audit and insurance requirements, including professional indemnity obligations.

Where you use the platform for immigration-related purposes, information about your immigration status may be shared with your employer as part of a job application or right-to-work assessment. Otherwise, data provided through one platform feature (for example, housing eligibility) is not shared with employers or other third parties unless you actively choose to include it.

The legal bases we use to process your personal data are as follows:

Consent

Direct Marketing

Where required, we will ask your permission if we want to deliver direct marketing to you and by direct marketing, we mean the communication directly to particular individuals of any advertising or marketing material.

If having given your consent you subsequently decide you no longer wish to receive direct marketing from us please log into your account with us and change your preferences.

Cookies and similar technologies

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 Cookies Notice and the information provided to you when those technologies are used.

Sensitive personal data (special category data and criminal offence data)

Where we process sensitive personal data — including health data, data relating to criminal convictions and offences, and immigration status — we rely on your explicit consent as the condition for processing under Article 9(2)(a) of the UK GDPR (and, for criminal offence data, under section 10 of the Data Protection Act 2018).

If you use the Platform directly, you provide this consent through a dedicated consent mechanism when you first accept our Terms of Business. This consent is separate from your general acceptance of the Terms of Business.

If your data is entered into the Platform by an employer, sponsor, or legal adviser acting on your behalf, they are contractually required to obtain your explicit consent before submitting your sensitive personal data. This obligation is set out in clauses 6.4 and 22.3 of our Terms of Business.

You may withdraw your consent at any time by contacting us at info@lawfairy.com. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Contractual Obligation

We will process your personal information to fulfil the contract we have with you. We rely on this legal basis to:

Provide products and services you have requested, including the eligibility-guidance tools (see purpose (f) above) and the job-application and recruitment features (see purpose (g) above), and manage our relationship with you. This may include managing requests, payments, access to products and services. This may also include sending you information and updates relating to the products and services we provide to you. Where necessary to provide the services you have chosen, we may also share your personal data with relevant third parties.

Legitimate Interest

We may use your information where there is a legitimate reason for us to do so, such as where it would help achieve our business objectives or to facilitate a benefit to you or someone else.

Our legitimate interests in processing personal data include:

to develop, deliver and maintain relevant products and services, including troubleshooting, data analysis, testing, system maintenance, cyber security, support, reporting and hosting of data;
understanding when and how you engage with us;
to build a clearer understanding of who our users and potential users are to better serve them;
to carry on our business, including managing complaints and requests and concerns that you may have about products or services we provide;
may send you service-related messages, which are about the service we provide. We do not require your consent for these, and you are not able to opt out;
to prevent fraud, check your identity, and prevent money laundering: We may use your information to check your identity in relation to requests you make. We may also have a legal obligation requiring us to carry out this activity;
to ensure our services are used appropriately; If you engage in any disruptive behaviour we may use the information that is available to us about you to stop such behaviour. This may involve informing relevant third parties, including your employer, law enforcement or other competent authorities about the content and your behaviour;
to provide you with help and support where we believe it is required. We may record phone calls or user enquiries via online chat for quality, training and management purposes;
to conduct market research and analytics, we may use the information we hold on you about your engagement with our products and services, to understand how our products are used and make improvements or develop other products and services our audiences may like. We may need to contact you about your experience of a product or service we provide you;
on a change of control or sale of our business, we may transfer, sell or assign any of the information described in this Privacy Notice to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business;
we also rely on legitimate interests for certain types of internal processing and for sharing personal data with our service providers and third parties as detailed in section 5 below.

To Comply With Legal Obligations & Protect Our Rights

We rely on this legal basis for the activities described in purposes (h) and (i) above, and more generally where we need to comply with legal and regulatory obligations or defend claims.

We may also disclose your information where we are allowed to by law to protect or enforce our rights or the rights of others and for the prevention and detection of crime, such as fraud.

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.

How we share your personal data

We may share your personal data — including identity information, contact details, CVs, application content and, where applicable, sensitive personal data such as health data and data relating to criminal convictions — with the following third parties:

In the HR platform, your personal data (including, where applicable, sensitive data) will be shared with the prospective employer and members of their group for the purposes of assessing your application.
In the Housing and Immigration platform, your personal data (including, where applicable, sensitive data) may be shared with legal advisers, charities, or other relevant parties based on your consent.
Your personal data may be shared with regulatory authorities (including the Solicitors Regulation Authority), courts, tribunals, and law enforcement agencies where required by law or in connection with legal proceedings.

Sensitive personal data is shared only where you have chosen to provide it (or where it has been provided on your behalf with your explicit consent) and in accordance with the consent given as described in section 4 above. All sensitive data is stored securely in our Dublin-based cloud environment and will be shared only with third parties in compliance with applicable data protection laws.

Data controller and processor roles for employers

Where employers use the platform, the data protection roles depend on the nature of the employer relationship:

Individual users (consumers, job applicants): LawFairy Limited is the data controller for all platform activities. LawFairy Services Limited is a joint controller for immigration-related processing only (regulated legal service).

Immigration sponsors (employer uses the platform for immigration/sponsorship): The sponsor employer is a data controller for employment-related purposes (deciding which employees to assess, managing sponsorship records). LawFairy Limited and LawFairy Services Limited are joint controllers for the immigration advice elements (FairyLogic analysis is a regulated legal service under the Immigration and Asylum Act 1999; LawFairy Services Limited has SRA obligations). LawFairy Limited also acts as a data processor for the narrow activity of storing and managing employee records at the sponsor's direction. These arrangements are governed by clause 23 of the Terms of Business.

HR/recruitment employers (employer uses the platform for job posting, recruitment — no immigration element): The employer is a data controller for recruitment purposes (deciding what roles to post, which candidates to consider). LawFairy Limited is a joint controller for platform purposes (determining what data to collect, how data flows, AI-assisted features, analytics). LawFairy Services Limited is not involved, as there is no regulated legal service element. LawFairy Limited also acts as a data processor for the narrow activity of storing and managing recruitment records at the employer's direction. These arrangements are governed by clause 6 of the Terms of Business.

In both employer scenarios, the employer is responsible for its own privacy notice covering its employment or recruitment-related processing.

Legal basis: performance of services you have requested, legitimate interest

We may pass your information to our processors — companies that we use to provide services on our behalf, for example, market research or other purposes mentioned in this Privacy Notice such as analytics, direct marketing or to ensure our products and services are used appropriately. These processors can only use your information in accordance with our instructions and for no other purpose.

Some features of the platform use third-party AI tools to help prepare application materials (for example, drafting job-questionnaire responses from the information in your CV). Where this is the case, your data is sent to the AI provider only as necessary and the AI provider processes it under its own terms.

AI features are not used for housing, immigration or citizenship guidance — those assessments use LawFairy's own tools and resources.

Legal basis: legitimate interest.

Legal basis: performance of services you have requested, legitimate interest. Consent

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.

Legal basis: legitimate interest.

International transfers

When you provide information to us, we may transfer your information to processors outside the UK to countries that may not have data protection rules that provide the same level of protection, including the United States of America. We would do this after having put in place appropriate agreements to ensure they protect your information in accordance with our legal obligations.

Legal basis: Performance of a contract, legitimate interest, consent

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.

Data retention

How long will you use my personal data for?

We will retain your information for as long as necessary for the uses set out in this Privacy Notice, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or while there is a legitimate reason for doing so.

Sensitive personal data provided through the HR platform will be subject to the data retention policies of the prospective employer. Any data shared with legal advisers or charities through the Housing and Immigration platform will be subject to those third parties' data retention policies. LawFairy is not responsible for third-party retention policies.

If you ask us to delete your information before that time, we may not be able to do so due to legal, regulatory or contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.

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 the event of a breach involving sensitive personal data, we will notify affected users as required by applicable laws. This may include email notifications, in-app alerts, or other appropriate communication methods, as mandated.

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.

If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account.

Personal information from closed accounts is retained in order to comply with legal obligations, prevent fraud, collect any fees owed and to resolve disputes.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to the personal data we hold about you, as follows:

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. There are some exemptions, which means you may not always receive all the information we process.
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, although 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 our 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:
1. If you want us to establish the data's accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. 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.
4. 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. In some instances, we may have an alternative legal basis to continue to process that personal information and we will inform you of that.

If you wish to exercise any of the rights set out above, please contact us at info@lawfairy.com.

These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.

You are not required to pay any charge for exercising your rights.

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.

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of the notice.

You have the right to make a complaint at any time to the Information Commissioner's 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.

If you wish to get in touch with us, please email us at info@lawfairy.com or write to us at The Data Protection Professional, LawFairy Limited, 180 The Strand, Level 2, Temple, London, WC2R 1EA