You can contact us via the following information channels: by mail: firstname.lastname@example.org; on data protection issues: email@example.com.
HUGO as the mediator of legal service is the controller in relation to the processing of personal data regarding the operation of the Platform and finding of a service provider through the Platform. In addition, HUGO is responsible for the transmission of offers and advertisements related to the mediation of legal aid services and for sending newsletters to the Client.
The moment when HUGO has provided the Client with information and the Client’s legal problem to the Lawyer, the Lawyer is the co-responsible processor of the Client’s personal data if the processing of personal data performed for the purpose of providing legal assistance.
Among other things, the Mediator of legal service (HUGO) and the Lawyer have agreed that:
— upon a registration of the Client, HUGO collects his personal data needed to the Lawyer;
— HUGO notifies the Client about the processing of his personal data with the aim of providing the legal aid;
— HUGO and the Lawyer shall ensure that the personal data of the Clients would not be accessible to persons not needing it, and use for this purpose the required technical and organizational measures;
During the provision of the service, HUGO may process your personal data regarding third parties and transfer your personal data to them. The “Authorized processor” of personal data is a natural or legal person, public authority, authority or other entity that processes personal data on behalf of the administrator (HUGO).
Principles of processing personal data
— Transparency – HUGO processes the Client’s personal data in a fair and transparent manner, and only where the Client has given its consent thereto, or the personal data of the Client is authorized to be processed by HUGO in accordance with law. HUGO shall use its best endeavours to ensure that the processing of personal data is as transparent and understandable to the Client as possible;
— Restriction of the Purpose – HUGO collects Client’s personal information for specified, explicit and legitimate purposes. HUGO shall not process the Client’s personal data later in a manner that would fail to comply with the initial processing purposes unless it is based on legal grounds or the Client’s permission.
— Collecting as little data as possible – HUGO will do its best to ensure that personal data processed by HUGO are adequate, relevant and limited to the purposes of processing;
— Fairness – the purpose of HUGO is to ensure that the Client’s personal data are correct and, where appropriate, relevant. We will do our best to delete or correct incorrect personal information immediately;
— Preservation Limit – We will preserve the Client’s personal data in a form that allows the Client to be identified only as long as it is necessary for the purpose of processing the personal data for which the Client’s personal data were collected. If the Client’s personal data are no longer needed and there is no legal basis for their continued processing, they shall be anonymised, deleted or destroyed;
— Reliability – We shall ensure that the Client’s personal data are processed by HUGO in a manner that safeguards the appropriate security of the personal data processed. Among other things, we shall do everything within our power to protect Client’s personal data from unauthorized or unlawful processing or accidental loss, destruction or damage;
— Integrated and tacit data protection – when developing, selecting and using applications, services and products based on personal data processing or when processing personal data, HUGO will be guided by the need for protection of personal data.
1. What personal data we process
- Name, phone number, email address, telephone number, personal identification code, place of residence.
- Description of the legal issue.
- Communication language.
- Time spent on providing legal aid.
- Cost of legal aid provided and payment details.
- Data on service issues and content of disputes.
2. The purpose of personal data processing
- We process personal information to bring the Customer together with the most appropriate lawyer via HUGO platform in order to settle the order for his / her preferred legal service aiming at ensuring fast, efficient, cost-effective, and transparently priced performance.
- We need a description of the client’s legal issue with the aim of bringing the Client together with the most suitable lawyer, taking into account the fields of specialization of the lawyer and the price category of the legal aid provided.
- We use client contact information to contact the Client through the HUGO platform.
- We use the name, telephone number and e-mail to communicate with the Client and to introduce the Legal Services to the Client.
- We collect information about the language of communication for the purpose of providing the client with communication with a lawyer in a language that the Client understands.
- We use the data related to a legal issue with the aim of mediating legal aid to the client, including choosing the lawyer offering the best service to the Customer by HUGO.
- We process the payment information of Clients in order to submit invoices to the Clients on behalf of the Lawyers with a purpose of processing the information on the legal issue provided by the Client, in order to collect data for the development of the robot lawyer.
- We process data to develop HUGO IT systems and services.
- Customer support information is collected on a case-by-case basis and retained for dispute resolution and for improving the quality of the service.
- We also collect data for statistical and financial analysis purposes.
- We process the data on time accounting necessary for billing purposes.
- We process data to comply with other legal obligations.
3. Legal grounds
- Agreement – Personal data are processed for the purposes of fulfilling the agreement. Personal data will be processed to enable mediation of legal services to the Client. Personal data will be processed to the extent in which the Clients transmit the data to the HUGO platform at the creation of the account and description of legal issue that needs to be resolved on the platform. The inevitable prerequisite for the use of the HUGO platform is the description of the legal issue related to the Client and the processing of personal data.
- Consent – based on your consent, HUGO processes personal information for the purposes of sending advertising and offers. Giving consent is voluntary and can be withdrawn at any time by notifying HUGO.
- Legitimate Interest – HUGO may process personal data of Platform Users on legitimate grounds (e.g., to ensure data and information security, platform development, fraud prevention) to ensure the security of the Platform and its e-service if Client’s interests and rights are not overwhelming under the given circumstances.
- Legal obligation – HUGO processes the Client’s personal data in order to comply with legal obligations arising from different legal acts (e.g. obligations under the legislation regulating the prevention of money laundering and terrorist financing).
4. Recipients to whom personal data are transmitted
- Client’s personal data are only provided to Lawyers who have activated the HUGO application. In this case, the Lawyer who has received the order, will see the client’s name, personal identification code, telephone number, e-mail address and description of the legal issue.
- For authorized data controllers.
- The Company will not disclose personal information to any third party not mentioned in this section, unless such right or obligation follows the law, or the Client has given an order to transfer the data to third parties (incl. authorization to act on behalf and for the client, i.e. representing the client in solving a legal problem).
- The Client’s assessment of the quality of legal aid is generally anonymous and the Lawyer cannot obtain the name or telephone number of the person who provided the assessment unless the Client has expressed his / her wish to disclose his / her data or if a disclosure of the data is necessary to resolve the client’s claim.
5. Security of personal data and access to data
- Personal data are stored on servers located on the territory of a Member State of the European Union and the access to personal data is made available to employees who may review personal data in order to resolve technical or customer support issues related to the use of the service.
- HUGO may process the project data in an anonymous form for the purposes of developing a robotic lawyer.
- HUGO administrators have the right to make queries on personal data in order to obtain statistical data on the use of the service (location of data subject by region; by field of law). When performing statistical queries, personal data are used in anonymised form.
- Data on geographic location is processed and personalization of data occurs when the location data need to be associated with a person for resolution of disputes or fraud.
- Data is processed anonymously for research or statistical purposes.
- Within the limits and to the extent permitted by law, queries concerning personal data may be subject to inquiries by a criminal investigation authority or court in the course of proceedings.
6. Access, correction and transfer of personal data
- The Clients have the right to correct their personal data. If the Client believes that the personal data concerning him / her is incorrect or incomplete, the Client has the right to correct the data on the HUGO platform himself or to request the correction or supplementation of such data by HUGO employees.
- The Client has the right at any time to obtain information about the scope and use of the processing of his / her personal data and to access the data concerning him / her. For this purpose, he / she must submit a handwritten or digitally signed application. The HUGO identifies the person before issuing personal data to exclude personal data from being transmitted to unauthorized persons.
- Personal data shall be stored as long as the Client has an active HUGO account. Closing the account will result in deletion of personal data unless the data is required for accounting, dispute or fraud resolution purposes.
- Following the provision of legal aid, i.e. after solving the problem, the Client’s personal data and the information about the solved legal problem (hereinafter also the Project), including data related to the latter, remain visible to the lawyer until the termination of the Customer Agreement. The Lawyer sees only the details of the projects that are / have been solved by him and which he has dealt with. This is necessary for the Lawyer to be able to resolve issues related to the provision of the service, including avoiding repeated requests for data from a person contacting the Lawyer with the same problem.
- Payment information for legal assistance provided to customers is stored for three years after the last invoice was issued.
- Accounting data is retained for seven years.
- For suspected crime, fraud or misrepresentation, data will be stored for 10 years.
- In case of payment disputes, the data will be stored until the claim is fulfilled or until the expiry of the limitation period.
- Data / history of customer related projects will be retained for three years after the end of the project, after which the information / history of the related projects will be anonymised.
- If the platform / application has not been used for three years, we will notify you of the existence of a Hugo account and to request a confirmation of your use of the account. If the use of the account is not confirmed, we will delete the personal data unless such data must be retained for the purpose of accounting, dispute resolution or fraud investigation and detection.
- Deletion of personal data is possible by deleting the HUGO user account. If you delete a user account, you will no longer be able to use the services of the HUGO platform.
- For deletion of data by HUGO, a self-signed or digitally signed application should be submitted. HUGO shall identify the person before deleting the personal data in order to exclude malicious requests from third parties.
- We will respond to the request for deletion of data within one month and specify the procedure for deleting the data.
9. Data transfer
- We will respond to your request for data transfer within one month and specify the details of the transfer. Customer support shall identify the person and transmit personal data, including the following: contact information, history and payment details of projects, related activities and documents.
10. Direct marketing communications
- We use the email address and / or phone number to send personalized direct marketing messages if you have given your consent on the HUGO platform.
- If the processing of Client personal data takes place following the Client’s consent, the Client shall have the right to withdraw the consent at any time by notifying HUGO that he or she does not wish to receive personal offers or advertisements, to continue processing of his / her data for the purpose of researching consumer habits and / or direct marketing, and / or transferring his / her data for this purpose to a third-party person.
11. Settlement of disputes
- Disputes related to the processing of personal data are resolved through customer support at firstname.lastname@example.org or by contacting Hugo data protection specialist email@example.com .
- The Supervisory Authority is the Estonian Data Protection Inspectorate (www.aki.ee, firstname.lastname@example.org).