DATA PROTECTION PRIVACY NOTICE
  - If you  have any questions about this privacy notice (“Notice”), please contact us by  email. 
- The  Business will process your and third parties’ personal data, as further  explained below, in the course of providing you with notarial and associated  services including access to our website and online features  (“Services”).
- We  will let you know, by posting on our website or otherwise, if we make any  changes to this Notice from time to time. Your continued use of the Services after  notifying such changes will amount to your acknowledgement of the amended  Notice. 
- PLEASE  NOTE: You shall and you hereby agree to indemnify the Business and its  affiliates and their officers, employees, agents and subcontractors (each an  “Indemnified Party”) from and against any claims, losses, demands, actions,  liabilities, fines, penalties, reasonable expenses, damages and settlement  amounts (including reasonable legal fees and costs) incurred by any Indemnified  Party arising out of or in connection with any breach by you of the warranties  included in this page.
What is Personal Data?
  - “Personal  data” means any information relating to an identified or identifiable natural  person, known as ‘data subject’, who can be identified directly or indirectly;  it may include name, address, email address, phone number, IP address, location  data, cookies and similar information. It may also include “special categories  of personal data” such as racial or ethnic origin, political opinions,  religious or philosophical beliefs, or trade union membership, and the  processing of genetic data, biometric data for the purpose of uniquely  identifying a data subject, data concerning health or data concerning a natural  person's sex life or sexual orientation.
- The Business may process personal data and special  categories of personal data which you provide in connection with the Services  about yourself and other data subjects, e.g. individuals whose details are  included in any materials provided by you to the Business. The Business may  obtain information about you and other data subjects from third party service  providers, such as due diligence platforms. If you use our online Services, the  Business may collect information about your devices including clickstream data. 
- The  provision of certain personal data is mandatory in order for the Business to  comply with mandatory client due diligence requirements and consequently to  provide the Services. You warrant on a continuous basis that such personal data  is accurate, complete and up to date. Failure to comply may result in documents  being rejected by the relevant certification authorities, held invalid in the  destination country or other difficulty to successfully completing the  Services.
- In relation to personal data of data subjects you  warrant to the Business on a continuous basis that:
- where applicable, you are authorised to share such  personal data with the Business in connection with the Services and that wherever  another data subject is referred to, you have obtained the explicit and  demonstrable consent from all relevant data subjects to the inclusion and use  of any personal data concerning them;
- to the extent this is required in connection with  the Services, such personal data is accurate, complete and up to date; and
- either  you provide your explicit consent and warrant that each data subject has  provided explicit consent for the transfer of personal data to foreign  organisations in connection with the Services as set out at on this page,  or that an alternative legal gateway for such transfer (such as transfer  necessary for the conclusion or performance of a contract concluded in the  interest of the data subject) has been satisfied. 
How do we use your personal data?
  - The Business will only process personal data, in  accordance with applicable law, for the following purposes:
- responding  to your queries, requests and other communications;
- providing  the Services, including, where applicable, procuring acts  from foreign organisations;
- enabling  suppliers and service providers to carry out certain functions on behalf of the  Business in order to provide the Services,including webhosting, data  storage, identity verification, technical, logistical, courier or other  functions, as applicable;
- allowing you to use features on our website, when  you choose to do so;
- ensuring  the security of the Business and preventing or detecting fraud;
- administering our Business, including complaints  resolution, troubleshooting of our website, data analysis, testing of new  features, research, statistical and survey purposes;
- developing  and improving our Services;
- complying  with applicable law, including Notary Practice Rules, guidelines and regulations or  in response to a lawful request from a court or regulatory body. 
- The legal basis for our processing of personal data for the purposes  described above will typically include:  
- processing  necessary to fulfil a contract that we have in place with you or other data  subjects, such as  processing for the  purposes set out in paragraphs (a),  (b),  (b)  and (d);
- your  consent, such as  processing for the  purposes set out
- processing  necessary for our or a third party’s legitimate interests, such as  processing for the purposes set out in  paragraphs (a),  (b), (b),  (e),  (f)  and (g),  which is carried out on the basis of the legitimate interests of the Business  to ensure that Services are properly provided, the security of the Business and  its clients and the proper administration of the Business;and
- processing  necessary for compliance with a legal obligation to which we are subject, such  as  processing for the purposes set out  in paragraph (h).and
- any  other applicable legal grounds for processing from time to time.
COOKIES
What exactly are cookies? 
  - In  order to collect the information including personal data as described in this  Notice, we may use cookies and similar technology on our website. A cookie is a  small piece of information which is sent to your browser and stored on your  computer’s hard drive, mobile phone or other device. You can set your browser  to notify you when you receive a cookie.This enables you to decide if you  want to accept it or not.However, some of the Services offered through  our website may not function properly if your cookies are disabled.
- Cookies  can be first party or third party cookies.
    - First  party cookies – cookies that the website you are visiting places on your  device.  
- Third  party cookies – cookies placed on your device through the website but by third  parties, such as, Google.  
The cookies placed on our website
	  We use  the following cookies on our website: 
  - Strictly  necessary cookies. These cookies are essential in order to enable you to move  around our website and use its features. Without these cookies, Services you  have asked for cannot be provided.They are deleted when you close the  browser. These are first party cookies. 
- Performance  cookies. These cookies collect information in an anonymous form about how  visitors use our website. They allow us to recognise and count the number of  visitors and to see how visitors move around the website when they are using it  and the approximate regions that they are visiting from. These are first party  cookies.
- Functionality cookies.  These cookies allow our website to remember choices you make (such as your user  name, language or the region you are in, if applicable) and provide enhanced,  more personal features. These cookies can also be used to remember changes you  have made to text size, fonts and other parts of web pages that you can  customise. The information these cookies collect may be anonymised and they  cannot track your browsing activity on other websites.  These are first party cookies. 
- Social Media cookies. These cookies allow you to  connect with social media networks such as LinkedIn and twitter. These are  persistent cookies which will be kept  on your device until their expiration or earlier manual deletion. 
- We may combine information from these types of  cookies and technologies with information about you from other sources.
Cookie consent and opting out
  - We assume that you are happy for us to place  cookies on your device. Most Internet browsers  automatically accept cookies. However, if you, or another user of your  device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your  browser setting. If you choose to decline cookies, you may not be able to fully  experience the interactive features of our website, our platforms and Services. 
Disclosure of personal data
  - There are circumstances where the  Business may wish to disclose or is compelled to disclose your personal data to  third parties. These scenarios include disclosure to: 
- our  subsidiaries or associated offices;
- our  suppliers and service providers to facilitate the  provision of the Services, including   couriers, translators, IT consultants and legalisation and other  handling agents, webhosting providers, identity verification partners (in order  to verify your identity against public databases), consultants, for example, in  order to protect the security or integrity of our business, including our  databases and systems and for business continuity reasons;
- public  authorities to carry out acts which are necessary in connection with the  Services, such as the Foreign Office; 
- foreign  organisations to carry out acts which are necessary in connection with the  Services, such as Embassies, Consulates and High Commissions;
- professional  organisations exercising certain public functions in relation to the  notaries profession, such as Chambers of Commerce;
- successor  or partner legal entities, on a temporary or permanent basis, for the purposes  of a joint venture, collaboration, financing, sale, merger, reorganisation,  change of legal form, dissolution or similar event relating to a Business. In  the case of a merger or sale, your personal data will be permanently  transferred to a successor company; 
- public  authorities where we are required by law to do so; and
- any  other third party where you have provided your consent.
International transfer of your personal data
  - We may  transfer your personal data to a third party in countries outside the country  in which it was originally collected for further processing in accordance with  the purposes set out above. In particular, your personal data may be  transferred to foreign organisations such as foreign Embassies located in the  UK or abroad. Such organisations will process personal data in accordance with  the laws to which they are subject and international treaties over which the  Business has no control.
- If the Business transfers personal  data to private organisations abroad, such as subcontractors, it will, as  required by applicable law, ensure that your privacy rights are adequately  protected by appropriate technical, organisation, contractual or other lawful  means. You may contact us for a copy of such safeguards in these circumstances. 
Retention of personal data
  - Your personal data will be retained  for as long as is reasonably necessary for the purposes listed above or as  required by the law. For example, the Notaries Practice Rules require that that  notarial acts in the public form shall be preserved permanently. Records of  acts not in public form shall be preserved for a minimum period of 12 years.  Please contact us for further details of applicable retention periods. Personal  data may for reasons of security and convenience be stored on remote data  facilities but in an encrypted form.
- We may keep an anonymized form of  your personal data, which will no longer refer to you, for statistical purposes  without time limits, to the extent that we have a legitimate and lawful  interest in doing so.
Security of personal data
  - The Business will implement  technical and organisational security measures in order to prevent unauthorised  access to your personal data.
- However, please be aware that the  transmission of information via the internet is never completely secure. Whilst  we can do our best to keep our own systems secure, we do not have full control  over all processes involved in, for example, your use of our website or sending  confidential materials to us via email, and we cannot therefore guarantee the  security of your information transmitted to us on the web. 
Data subject rights
  - Data subjects have numerous rights  in relation to their personal data. For further information about your data  protection rights please visit the ICO website.
- Right  to make a subject access request (SAR). Data subjects may request in writing  copies of their personal data. However, compliance with such requests is  subject to certain limitations and exemptions and the rights of other data  subjects. Each request should make clear that a SAR is being made. You may also  be required to submit a proof of your identity and payment, where applicable. 
- Right  to rectification. Data subjects may request that we rectify any  inaccurate or incomplete personal data.  
- Right  to withdraw consent. Data subjects may at any time withdraw their  consent to the processing of their personal data carried out by the Business on  the basis of previous consent. Such withdrawal will not affect the lawfulness  of processing based on previous consent.
- Right  to object to processing, including automated processing and profiling. The  Business does not make automated decisions. 
- Right  to erasure. Data subjects may request that we erase their  personal data. We will comply, unless there is a lawful reason for not doing  so. For example, there may be an overriding legitimate ground for keeping the  personal data, such as, our archiving obligations that we have to comply with. 
- Restriction. Data subjects may request that we restrict our processing of their  personal data in various circumstances. We will comply, unless there is a  lawful reason for not doing so, such as, a legal obligation to continue  processing your personal data in a certain way.
- Right  to data portability.In certain circumstances, data subjects may  request the controller to provide a copy of their personal data in a  structured, commonly used and machine readable format and have it transferred  to another provider of the same or similar services. To the extent such right  applies to the Services, we will comply with such transfer request. Please note  that a transfer to another provider does not imply erasure of the data  subject’s personal data which may still be required for legitimate and  lawful purposes.
- Right  to lodge a complaint with the supervisory authority. We suggest that  data subjects contact us about any questions or complaints in relation to how  we process personal data. However, each data subject has the right to  contact the relevant supervisory authority directly.