Privacy policy

“us”, “our”). The Business is registered with the Information Commissioner’s Office (“ICO”) under
number Z211761X.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 paragraph 8.
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:
(a) 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;
(b) to the extent this is required in connection with the Services, such personal data is accurate,
complete and up to date; and
(c) 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 paragraph 18, or that an alternative legal gateway for such transfer (such as transfer
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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
(a) responding to your queries, requests and other communications;
(b) providing the Services, including, where applicable, procuring acts from foreign organisations;
(c) 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;
(d) allowing you to use features on our website, when you choose to do so;
(e) sending you personalised marketing communications requested by you, as well as serving
personalised advertising to your devices, based on your interests in accordance with our
Cookie Statement below. You have the right to disable cookies
(f) ensuring the security of the Business and preventing or detecting fraud;
(g) administering our Business, including complaints resolution, troubleshooting of our website,
data analysis, testing of new features, research, statistical and survey purposes;
(h) developing and improving our Services;
(i) 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
• 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 in paragraph (e);
• processing necessary for our or a third party’s legitimate interests, such as processing for the
purposes set out in paragraphs (a), (b), (b), (f), (g) and (h), 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 (i).and
• any other applicable legal grounds for processing from time to time.
Cookie statement
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 websiteWe use the following cookies on our website:
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• 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.
• Targeting or advertising cookies. These cookies allow us and our advertisers to deliver
information more relevant to you and your interests. They are also used to limit the number of
times you see an advertisement as well as to help measure the effectiveness of advertising
campaigns. They remember that you have visited our website and may help us in compiling your
profile. These are persistent cookies which will be kept on your device until their expiration or
earlier manual deletion.
• 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 outWe 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.When you arrive on our website a pop-up message will appear asking for your consent to place
advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once
your consent has been provided, this message will not appear again when you revisit. If you, or another
user of your device, wish to withdraw your consent at any time, you can do so by altering your browser
settings otherwise we will assume that you are happy to receive cookies from our website. For more
information please visit and
Disclosure of personal dataThere 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;
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• subject to your consent, our advertising and marketing partners who enable us, for example,
to deliver personalised ads to your devices or who may contact you by post, email, telephone,
SMS or by other means;
• 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 dataWe 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 dataYour 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 dataThe 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 rightsData 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
• 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.
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• Right to object to processing, including automated processing and profiling. The Business
does not make automated decisions. Profiling may be carried out for Business administration
purposes, such as monitoring trends in user visits of our website, and in order to deliver targeted
ads. The Business may use third party due diligence platforms which provide recommendations
about data subjects by automated means. We will comply with any data subject’s objection to
processing unless we have a compelling overriding legitimate ground for the processing, the
processing is for the establishment, exercise or defence of legal claims or we have another lawful
reason to refuse such request. We will comply with each valid opt-out request in relation to
marketing communications.
• 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
• 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.