Privacy Policy

Legal Marketplace Pty Ltd trading as Finchly (“us” “we” or “our”) is committed to earning and maintaining your trust by managing your personal information in accordance with all applicable State and Commonwealth laws. This Privacy Policy applies to Legal Marketplace Pty Ltd trading as Finchly (ABN: 53 676 482 509) and provides important information about how we collect, use, hold, and disclose your personal information. It also outlines how you can:

• access and correct the personal information we hold about you
• make a complaint about our handling of your personal information
• provide free and informed consent for Finchly to handle your personal information.

By accessing Finchly websites and by using our products or services, you consent to the terms of this Policy and the Finchly Terms & Conditions and agree to be bound by them. This policy is also incorporated by reference into the Finchly Terms & Conditions that apply to products and services provided by us. What laws apply to us when we collect, use, or disclose your personal information Our collection, use, holding, and disclosure of your personal information is governed by the Australian Privacy Principles and the Privacy Act 1988 (Cth) as well as State and Territory privacy legislation where applicable. Types of personal information we collect and the purpose for collection "Personal Information" is taken to mean any information or opinion about a person or otherwise relating to a person where that person is identified or could be identified. We collect, hold, use, and disclose personal information so that we can offer and deliver to you and end users Finchly products and related services. These services include, but are not limited to, collection and publishing of feedback, facilitating enquiries and communication between consumers and legal practitioners, and ability for consumers (perhaps “end users”) to manage the feedback left. The personal information we collect depends on the products and services we offer you and the circumstances of your interactions with us. The kinds of personal information we may generally collect from you and hold may include:

• identity information such as your name, age or date of birth, contact details (including address, email address, phone number, and mobile phone number), occupation pertaining to your legal practice specialty, usernames or passwords
• information that you enter or upload into the Finchly platform including information about others.

The information that Finchly collects and the retention period is as follows: Individual User Information (Consumer)

Type of Information	Retention Period
Name	7 years
Email	7 years
Phone number	7 years
Profile photo	7 years
A user can leave feedback on Finchly on a lawyer or law firm which contains the following: Overall Rating Comment Ratings on service areas Private comment for the law firm The lawyer responsible	No limit
A user can submit an enquiry containing the following: Area of law the enquiry pertains to Message to the lawyer or law firm	No limit

Lawyer and Law Firm Information

Type of Information	Retention Period
First name and last name	7 years
Contact email	7 years
Contact phone number	7 years
Profile photo	7 years
Title	7 years
Company logo	7 years
Matter count and area of specialisation	7 years
Past employment experience: Employer Title Duration of employment	7 years
Information about clients (in order to generate feedback request): Contact information Matter type Matter status Lawyers assigned	2 years

Without these details we may not be able to carry on our business and provide you with the products or services you require or the level of services which we aim to offer. We may also use your personal information for additional purposes such as:

• conducting customer research
• marketing our products and services to you
• personalising or targeting advertisement on other websites, apps or online platforms
• data analysis and matching for marketing purposes
• using web tracking tools and cookies to manage or improve our website
• improving our products and services.

We may share your personal information with others as part of our product offering. What information we share and with whom depends on the circumstances of the activities we need to perform. For example, we may also share your personal information with marketing, advertising, and data matching service providers and third-party platforms which display advertising or content (including personalised advertising) based on your personal information. We support your right to access or correct the personal information we hold about you or make a privacy complaint. How we collect and hold your personal information Personal information about you may be collected by us in a number of ways including over the phone and via email, from devices or browsers which you use to access our subscription services and webpages, other webpages where we keep a record and a copy of your contact with us, where you submit information through web forms, by logging your IP address, collecting GPS data, by use of cookies, by recording phone numbers and email addresses from which you contact us, by any smart phone, browser, plugin or other application we use which might collect information from the device or browser used by you and in other ways which rely on technical access to information available from devices and operating systems that you might use. We may also obtain your personal information from our affiliates or advertising partners, clients, contractors, customers and other third parties such as survey or competition websites, marketing websites, any other websites accessible via our website that we consider helps us to deliver or advertise our services, understand online activity and collect information that we consider important to managing the quality or content of the services that we deliver. Once we have collected your personal information we may hold it electronically or in paper files. Why we collect, hold, use, and disclose your personal information We endeavor to limit the collection of your personal information to what is reasonably necessary for our business activities and functions. We collect, hold, use, and disclose your personal information for the following purposes:

• to perform and manage our business functions or activities including providing our products or services to you and end customers
• to manage our relationship with you as legal practitioners and/or customers
• to review, process, assess, and update your profile and feedback provided by legal practitioners and end customers
• to improve our products and services and/or develop new products and/or services
• to undertake customer market research
• to market and advertise our services and the services of other entities with whom we have relationships, including entities that market and promote goods and services unrelated to those which we market and promote and for the operation of the businesses of third parties including the supply of products or services by those third parties
• to assist legal practitioners gain approval to be connected with end customers for particular legal services rendered
• to research, design, develop, manage, provide, and improve our products and services
• to contact you
• to comply with laws and assist government licensing or law enforcement agencies
• to undertake acts or practices related to the matters described above.

We may also collect, hold, use, and disclose your personal information for other reasons where the law allows or requires us to do so. We retain the right to use or disclose personal information about you that is required in the provision of information about or the promotion or delivery of Finchly services (including by way of direct marketing through mail, telephone, email, SMS and MMS messages, and any other electronic means) to our users and customers, such as newsletters, promotional materials, or direct marketing campaigns relevant to the products and services that we offer. If you no longer wish to receive our direct marketing emails or SMS and MMS messages, please follow the Unsubscribe link or statement located in all emails or SMS and MMS messages that we send to you or let us know by using the details provided in the section titled "Contacting us" below. Who we disclose your personal information to Who we disclose your personal information will depend on our relationship with you and the purposes for which we collected your personal information. In some circumstances, the entities we share information with may also share your personal information with other entities they do business with. We may also disclose your personal information to people or organisations outside of Finchly for the purposes noted in the "Why we collect, hold, use, and disclose your personal information" section above and to other parties and for other purposes as specified below: This may include:

• organisations who manage some of our business activities and functions including call centre services, marketing, corporate administration and corporate strategies
• service providers including share registry service providers, IT service providers, and sponsors and/or promoters
• organisations with whom Finchly has a business relationship (e.g. partners, joint venture entities, agents, contractors, or external service providers) for the operation of their businesses
• third party payment processing providers or debt recovery agencies in connection with billing or payment for the provision of services to Finchly users or customers
• the police or other relevant authorities, licensing or enforcement bodies
• government and regulatory authorities or organisations (such as ASX or ASIC) or as otherwise required or authorised by law
• internet service providers or network administrators, including in circumstances where there is suspected interference with or use of our website, platform or other applications or systems or where there is any suspected violation of the rights of a third party
• social media platforms, search engines, or other third parties which publish or advertise our services or assist us to undertake marketing or analysis for marketing purposes
• other entities as permitted or required by law or regulation
• lawyers, accountants, auditors, contractors, and other advisors or service providers who may need access to information for the purpose of advising us or managing our business activities.

Accessing or correcting your personal information We take steps reasonable in the circumstances to ensure that the personal information we hold is accurate, complete, up-to-date, relevant, and not misleading. We encourage you to regularly review your personal information and to advise us of any changes. You have the right to access the personal information we hold about you. You also have the right to request correction of the personal information we hold about you. If you would like to access or correct your personal information, please contact us using the details provided in the "Contacting us" section below. We will try to provide the information or make the changes within a reasonable time period and in the manner requested by you, if it is reasonable and practicable for us to do so. In certain circumstances, we may not be able to give you access to the personal information we hold about you or we may not agree to make the changes that you have requested. If this is the case, we will provide reasons for our decision as required by law. Making a privacy complaint We take your privacy concerns seriously and we will do our best to address them. If you have a concern about the way we have handled your personal information, please contact us using the details provided in the "Contacting us" section below. We will try to respond to your complaint within a reasonable time period and in a manner that is fair and reasonable. If you are not satisfied with our response, you may also contact the Office of the Australian Information Commissioner (OAIC) or the relevant state or territory privacy commissioner. The OAIC’s contact details are as follows: Office of the Australian Information Commissioner (OAIC) Website: https://www.oaic.gov.au Phone: 1300 363 992 Email: enquiries@oaic.gov.au Contacting us If you have any questions, concerns, or complaints about this Privacy Policy, please contact us using the details below: Legal Marketplace Pty Ltd trading as Finchly Website: https://www.finchly.com.au Email: support@finchly.com.au Changes to this Privacy Policy We may update this Privacy Policy from time to time. When we do, we will post the updated policy on our website and it will be effective as of the date of posting. We encourage you to review this Privacy Policy periodically to stay informed about how we are managing your personal information.