Introduction

This privacy policy will inform you as to how I look after your personal data when you visit my website and tell you about your privacy rights and how the law protects you. 

1. Important information 

Purpose of this privacy policy

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you use my services. 

This website is not intended for children and I do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. 

Controller

I am the controller and responsible for your personal data. If you have any questions about this privacy policy or our privacy practices, please contact me using the details below:

Baljinder K Manak

bal@bmnotarypublic.co.uk

15 Hope Shield, Washington, NE38 9JF 

07763 444 585

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact me in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This privacy policy is kept under regular review. This version was last updated in August 2018. 

It is important that the personal data that I hold about you is accurate and current. Please keep me informed if your personal data changes.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website or app you visit.

2. The data I collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use my website and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from me and third parties and your communication preferences.

I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I will treat the combined data as personal data which will be used in accordance with this privacy policy.

I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

If you fail to provide personal data

Where I need to collect personal data by law, or under the terms of a contract that I have with you, and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you notarial services). In this case, I may have to cancel the service you have with me but I will notify you if this is the case at the time. 

3. How is your personal data collected?

I use different methods to collect data from and about you including through:

• Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply to use my notarial services;
  • request marketing to be sent to you;
  • or give me feedback or contact me. 
• Automated technologies or interactions. As you interact with my website, Technical Data will be automatically collect about your equipment, browsing actions and patterns. This personal data is collected by using cookies and other similar technologies. 

4. How your personal data is used

I will only use your personal data when the law allows us to. Most commonly, I will use your personal data in the following circumstances:

• Where I need to perform the contract for notarial services that I am about to enter into or have entered into with you.
• Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where I need to comply with a legal obligation.

You have the right to withdraw consent to marketing at any time by contacting me.

Purposes for which your personal data will be used

I will only process your personal data for the following purposes:

a) responding to your queries, requests and other communications;

b) providing notarial services, including, where applicable, procuring acts from foreign organisations; 

c) enabling suppliers and service providers to carry out certain functions in order to provide notarial services, including webhosting, data storage, identity verification, technical, logistical, courier or other functions, as applicable; 

d) allowing you to use features on my 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 my Cookie Statement below. You have the right to disable cookies as set out above or to unsubscribe. 

f) ensuring the security of my business and preventing or detecting fraud; 

g) administering my business, including complaints resolution, troubleshooting of my website, data analysis, testing of new features, research, statistical and survey purposes; 

h) developing and improving my notarial 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 processing of personal data described above will typically include:

• your consent, such as processing for the purposes set out in paragraph (e);
• processing necessary for my 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 my business to ensure that notarial services are properly provided, the security of my business and its clients and the proper administration of my business; and
• processing necessary for compliance with a legal obligation to which I am subject, such as processing for the purposes set out in paragraph (i); and
• any other applicable legal grounds for processing from time to time.

Marketing 

I will provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which services and offers may be relevant for you (this is called marketing). 

You will receive marketing communications from me if you have requested information from me and you have not opted out of receiving that marketing.

Third-party marketing 

I will not share your personal data with any third party for marketing purposes. 

Opting out

You can ask me to stop sending you marketing messages at any time by emailing me. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

My website may use cookies to distinguish you from other users of our website. This helps to provide you with a good experience when you browse the website and also allows to improve the website.

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The following cookies are used:

• Strictly necessary cookies. These are cookies that are required for the operation of my website. They include, for example, cookies that enable you to log into secure areas of my website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around my website when they are using it. This helps us to improve the way my website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to my website.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. I will use this information to make my website and the advertising displayed on it more relevant to your interests. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Change of purpose 

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me. 

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow any third-party service providers that I use to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

I do not transfer your personal data outside the European Economic Area (EEA) unless you have instructed solicitors to deal with your transaction outside of the EEA. If this is the case, whenever personal data is transferred outside of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 
• Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact me if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

7. Data security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality. 

I have put in place procedures to deal with any suspected personal data breach and I will notify you and any applicable regulator of a breach where I am legally required to do so.

8. Data retention

How long will you use my personal data for?

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.

To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances I will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including right to:

• access your personal data;
• correct your personal data;
• erase your personal data;
• object to processing of your personal data;
• restrict processing of your personal data;
• transfer your personal data; and
• withdraw consent.

If you wish to exercise any of the rights set out above, please contact me at bal@bmnotarypublic.co.uk.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated. 

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for the legitimate interests of my business. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess the legitimate interests of my business against any potential impact on you in respect of specific activities by contacting me.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that I am subject to.

THIRD PARTIES

External Third Parties

• Service providers;
• 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; The Notaries Society and the Faculty Office
• Professional advisers including lawyers, bankers, auditors and insurers; and
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: 

• If you want me to establish the data's accuracy.
• Where my use of the data is unlawful but you do not want me to erase it.
• Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I have used the information to perform a contract with you. 

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain services to you. I will advise you if this is the case at the time you withdraw your consent.