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DATA PROTECTION

 As  a notary public, Angharad holds personal data about her clients.  Accordingly she is registered with the Information Commissioner's Office  under registration number ZA183649.

In  order to comply with data protection rules, Angharad has a data  protection policy. In accordance with that data protection policy,  Angharad is obliged to provide a privacy notice to her clients.  This  privacy notice is set out below.​​


​DATA PROTECTION PRIVACY NOTICE

The  business of Angharad Mary Palin of 3 Berkley Road, Beaconsfield, HP9  2AY (“Business”) The Business is registered with the Information  Commissioner’s Office (“ICO”) under number ZA183649.

 If you have any questions about this privacy notice (“Notice”), please contact Angharad Palin at apalin@palinnotary.co.uk.

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 9.

1. What is Personal Data?
1.1 “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.

1.2 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.

1.3 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.

1.4 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  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.

2. How do we use your personal data?
2.1 The Business will only process personal data, in accordance with applicable law, for the following purposes:

as responding to your queries, requests and other communications;
providing the Services, including, where applicable, procuring acts from foreign organisations;

b) 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;

c) allowing you to use features on our website, when you choose to do so;

d) 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;

e) ensuring the security of the Business and preventing or detecting fraud;

f) administering our Business, including complaints resolution,  troubleshooting of our website, data analysis, testing of new features,  research, statistical and survey purposes;

g) developing and improving our Services;

h) complying with applicable law, including Notary Practice Rules,  guidelines and regulations or in response to a lawful request from a  court or regulatory body.

2.2 The legal basis for our processing of personal data for the purposes described above will typically include: 

a) processing necessary to fulfill a contract that we have in place with  you or other data subjects, such as  processing for the purposes set out in paragraph 2.1  (a), (b), (c) and (d);;

b) your consent, such as processing for the purposes set out in paragraph 2.1 (e);

c)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

d) any other applicable legal grounds for processing from time to time.

3. Cookie statement
3.1 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.

3.2 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.

3.3 The cookies placed on our website
We use the following cookies on our website:
a) 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.
b) 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.
c) 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.
d) Targeting or advertising cookies. We  are not aware of any of these cookies on our website at the present  time but include this description for completeness. 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.
e) 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.

3.4 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.

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.

4. 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:
4.1 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;
4.2 professional organisations exercising certain public functions in  relation to the notaries profession, such as Chambers of Commerce;
4.3 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;
4.4 public authorities where we are required by law to do so; and
4.5 any other third party where you have provided your consent.

5. International transfer of your personal data
5.1 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.

5.2 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.

6. Retention of personal data
6.1 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.

6.2 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.

7. Security of personal data
7.1 The  Business will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.

7.2 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.

8. Data subject rights
8.1 Data  subjects have numerous rights in relation to their personal data. For  further information about your data protection rights please visit the  ICO website.

a) 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.
b) Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete personal data. 
c) 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.
d) 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.
e) 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.
f) 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.
g) 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.
h) 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.

Copyright © 2025 Angharad Palin, Notary Public - All Rights Reserved.

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