DATA PROTECTION POLICY
GILLIAN CLARE ANDERSON NOTARY PUBLIC
DATA PROTECTION PRIVACY NOTICE
1. I, GILLIAN CLARE ANDERSON of Alsa Deane Holmbush Downgate Near Callington Cornwall PL17 8HF (“Business”, “I’, “we”, “us”, “our”). The Business is registered with the Information Commissioner’s Office (“ICO”) under number Z166952X
1. If you have any questions about this privacy notice (“Notice”), please contact us by email.
1. 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”).
1. 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.
1. 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 paragraphs 8 & 9.
What is Personal Data?
1. “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.
1. 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.
1. 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.
1. 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 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?
1. The Business will only process personal data, in accordance with applicable law, for the following purposes:
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 as set out above or to unsubscribe by clicking here;]
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 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), (c) 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), (c), (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.