THE LAWYER GUIDE SINGAPORE

1. About This Policy

The Lawyer Guide Pte Ltd (UEN: 202640664K) ("the Company", "we", "us") operates The Lawyer Guide in Singapore, available at thelawyerguide.com ("the Platform"). We are the organisation responsible for personal data processed through the Platform under the Personal Data Protection Act 2012 (PDPA).

This Policy explains what information we collect, how and why we use or disclose personal data, how long we keep it, and the rights available under Singapore law. It should be read together with our Terms and Conditions and any Review Policy or other notice shown when you use a particular feature of the Platform.

The Singapore Platform is operated by the Company for the Singapore market. We may use service providers, professional advisers, affiliated companies, or support personnel where reasonably necessary to operate and support the Platform. Any access to or transfer of personal data is subject to the safeguards described in this Policy and applicable Singapore law.

This Policy may be updated from time to time. The current version is always available on the Platform.

2. Personal Data We Collect

We collect or receive information in the following situations:

• When you submit a review of a lawyer
• When you request legal help or ask to be connected with a lawyer
• When a lawyer accesses, claims, verifies, or manages a profile on the Platform
• When you contact us directly, by email or otherwise
• When you sign up for or consent to marketing communications
• When you visit or use the Platform
• When we compile professional information about lawyers from official registers and other publicly available professional sources

Information about lawyers

Lawyer profiles may contain a lawyer's name, professional title, business contact details, law practice or firm affiliation, practising status, areas of practice, years of experience, and other professional information. This information may come from official registers, law practice websites, other publicly available professional sources, or directly from the lawyer.

When a lawyer claims or manages a profile

We may collect an email address, account authentication information, contact details, profile descriptions, practice areas, related keywords, firm affiliation, account settings, and other professional information the lawyer chooses to provide.

When you submit a review

We collect the content of the review and any contact, verification, or other information requested through the review process. Reviews displayed publicly are ordinarily shown without the reviewer's name or contact details. We may retain information needed to verify, moderate, investigate, or respond to questions about a review.

When you request legal help

We may collect your name, email address, telephone number if provided, the type of legal help you are seeking, and information you choose to provide about your legal matter. Depending on what you submit, this information may be sensitive. You should provide only information reasonably necessary for us and the lawyer or law practice receiving the request to understand and respond to your enquiry.

When you use the Platform

We may collect technical and usage information such as IP address, browser and device information, pages viewed, timestamps, security logs, and information collected through cookies or analytics tools.

3. How and Why We Use Personal Data

The PDPA generally requires consent for the collection, use, or disclosure of personal data unless an exclusion, exception, or other permitted basis applies. Different parts of the Platform rely on different bases under Singapore law.

a) Publishing lawyer profiles

The Platform helps members of the public find, evaluate, and compare legal professionals in Singapore. Under the PDPA, business contact information, such as a person's name, professional title, business telephone number, business address, and business email address, is generally outside the main Data Protection Provisions when it is provided for business purposes.

For other lawyer profile information that is already publicly available, we may collect, use, and disclose that information without consent where the publicly available information exception under the PDPA applies. Where profile information is neither business contact information nor covered by another applicable exception, we may rely on another permitted basis, including the legitimate interests exception where appropriate.

Where we rely on legitimate interests, we assess the purpose, identify potential adverse effects on the individual, implement reasonable measures to reduce those effects, and determine that the legitimate interest outweighs any remaining adverse effect. We retain the required assessment for as long as we rely on it. Lawyers may ask us to correct, update, or consider removal of profile information as described in section 9.

b) Publishing and moderating reviews

When a reviewer submits a review, we use the reviewer's personal data to receive, verify, moderate, publish, administer, and, where necessary, investigate the review. Where consent is required, it is obtained through the review submission process.

Personal data about the lawyer who is reviewed is processed separately from the reviewer's consent. Depending on the information involved, we rely on the treatment of business contact information under the PDPA, the publicly available information exception, or the legitimate interests exception. Where legitimate interests is relied on, our assessment takes into account the value of genuine client experiences to users of the Platform and the potential impact on the lawyer, together with measures such as moderation and a review dispute process.

c) Responding to requests for legal help

If you ask us to help you find legal assistance, we use the information you provide to process your request and may disclose it to one or more lawyers or law practices that may be relevant to the request. We use that information for the purpose of facilitating your enquiry and responding to your request. We do not use information about your legal matter for unrelated marketing unless you have separately agreed to receive marketing communications.

d) Operating lawyer accounts and profiles

We use account and profile information to verify users, provide account functionality, maintain profile information, communicate about the account or Platform, prevent misuse, and keep the service secure.

e) Operating, securing, and improving the Platform

We use technical, security, cookie, and usage information to provide the Platform, prevent fraud or misuse, diagnose technical issues, maintain security, understand how the Platform is used, and improve our services. We rely on consent where required and on other permitted bases under the PDPA, including legitimate interests where appropriate and supported by the required assessment.

f) Marketing

We use personal data for direct marketing only where permitted by applicable law. Where consent is required, we request it separately. We do generally not rely on the PDPA legitimate interests exception as the basis for sending direct marketing communications.

4. Sharing Personal Data with Others

We disclose personal data only where reasonably necessary for the purposes described in this Policy, where you have requested or consented to the disclosure, or where the law otherwise permits or requires it.

This may include disclosure to:

• Lawyers or law practices where you ask us to connect you with legal help
• Service providers that support hosting, analytics, email delivery, security, customer support, communications, and other Platform operations
• Professional advisers, auditors, insurers, or other advisers where reasonably necessary for legal, regulatory, risk, or business purposes
• Affiliated companies or support personnel where they provide services to the Singapore Platform and access is limited to what is necessary for that purpose
• Courts, regulators, law enforcement authorities, or other persons where disclosure is required or permitted by law

Affiliated companies do not receive personal data collected through the Singapore Platform for their own independent marketing purposes unless you have separately agreed to that use.

5. Transfers Outside Singapore

Some service providers, affiliated companies, or support personnel we use may be located outside Singapore or may access personal data from outside Singapore. Before transferring personal data outside Singapore, we take the steps required by the PDPA Transfer Limitation Obligation to ensure that the transferred personal data receives a standard of protection comparable to the protection under the PDPA, unless an applicable exemption applies.

6. How Long We Keep Personal Data

We cease retaining personal data, or remove the means by which it can be associated with an individual, when it is reasonable to assume that the purpose for which the data was collected is no longer served by retention and retention is no longer necessary for legal or business purposes.

In practice:

• Lawyer profile information may be retained while the lawyer is practising and the information continues to serve the directory purpose, subject to correction, updating, removal requests, and applicable law
• Reviews may be retained while they continue to serve the purpose of helping users evaluate lawyers, subject to our review moderation and dispute process and any legal retention requirements
• Information submitted through a request for legal help is kept only for as long as reasonably needed to handle the request and any related legal or business requirements, unless you separately consent to further use
• Lawyer account information is kept while the account is active and for an appropriate period afterwards where necessary for security, dispute, legal, or business purposes
• Technical, security, cookie, and analytics data is kept only for as long as reasonably necessary for the purpose for which it was collected, including periods configured in the tools we use
• Marketing preference and opt-out records may be retained for as long as reasonably necessary to respect and demonstrate your communication preferences

7. Accuracy, Data Security, and Data Breaches

We take reasonable steps to ensure that personal data is accurate and complete where it is likely to be used to make a decision that affects an individual or disclosed to another organisation. Lawyers can help us keep professional information current through the profile correction process described in section 9.

We maintain reasonable security arrangements designed to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, and against the loss of any storage medium or device on which personal data is stored. Depending on the nature of the data and system, these arrangements may include access controls, authentication measures, encryption, logging, backups, and contractual or organisational controls over service providers.

If a data breach occurs, we assess it in accordance with the PDPA. Where a breach is notifiable, we notify the Personal Data Protection Commission and affected individuals as required by Singapore law.

8. Marketing Communications

Where we send commercial electronic messages, we comply with applicable Singapore marketing rules, including the Spam Control Act where it applies. Marketing emails include a method to opt out. Where marketing by telephone, text message, or other message to a Singapore telephone number is involved, we comply with the Do Not Call provisions of the PDPA unless an applicable consent or exception permits the communication.

You can withdraw consent to marketing or opt out at any time. Opting out of marketing does not remove a lawyer profile or account and does not prevent us from sending service, security, legal, or administrative communications that are reasonably necessary for the Platform or an account.

9. Correction, Updating, and Removal of Lawyer Profiles

If you are a lawyer and believe a profile contains incorrect or outdated information, or you want us to consider removing information or the profile, contact us at singapore@thelawyerguide.com or privacy@thelawyerguide.com . We aim to acknowledge requests within two business days.

We assess profile requests on their facts, including the accuracy of the information, its source, whether it is business contact information or publicly available information, the purposes of the Platform, any applicable legitimate interests assessment, and Singapore law. A request for removal is therefore not treated as an automatic statutory deletion request, but we will consider it fairly and respond to the lawyer concerned.

10. Your Rights Under the PDPA

Subject to the PDPA and its exceptions, you may:

• Request access to personal data about you that is in our possession or under our control
• Request information about how that personal data has been used or disclosed within the year before your request
• Request correction of an error or omission in personal data about you that is in our possession or under our control
• Withdraw consent to our collection, use, or disclosure of your personal data where consent is the basis for that processing, with reasonable notice and subject to being informed of the likely consequences of withdrawal

Singapore law does not provide a general right to deletion or a general right to object to processing equivalent to those found in some other jurisdictions. The PDPA contains a statutory data portability obligation, but at the date of this Policy that obligation is not yet in force. Where you would like data removed or your involvement with the Platform ended, contact us and we will consider the request under this Policy, our Terms and Conditions, and applicable law.

11. How to Exercise Your Rights or Raise a Concern

Send requests or questions to privacy@thelawyerguide.com . We may ask for information reasonably necessary to verify your identity and understand the request. We aim to acknowledge requests within two business days and respond as soon as reasonably possible or practicable, as applicable under the PDPA.

If we cannot comply with a valid access or correction request within 30 days after receiving a request made in accordance with the applicable PDPA requirements, we will inform you in writing within that period of the time by which we expect to respond. Access and correction rights are subject to the exceptions and procedures under Singapore law.

If you believe we have not handled your personal data in accordance with the PDPA, please contact us first so that we can review the concern. You may also lodge a complaint with the Personal Data Protection Commission of Singapore at pdpc.gov.sg .

12. Data Protection Officer

Our Data Protection Officer is François Théo Savard. The Data Protection Officer can be contacted at privacy@thelawyerguide.com .

13. Changes to This Policy

We may update this Policy from time to time to reflect changes to the Platform, our practices, or applicable law. The current version and effective date are always shown on the Platform.

14. Contact

For questions about this Policy or how we handle personal data, contact privacy@thelawyerguide.com .

For matters relating to The Lawyer Guide generally, contact support@thelawyerguide.com .