1. The business of Alexandria Sarah Cartledge of 12 West Avenue Filey YO14 9AA trading as Bayle Legal (“Business”, “we”, “us”, “our”) is registered with the Information Commissioner’s Office (“ICO”) under number ZB848518.
2. If you have any questions about this privacy notice (“Notice”), please contact us by e-mail.
3. 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”).
4. 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.
5. 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 and 7.
Personal data
6. “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.
7. 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.
8. 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.
9. 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 we use personal data
10. 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. enabling our supervisor, as defined in the Notaries (Post-Admission Supervision and Training) Rules 2019, to carry out their role during our period of practice under supervision as defined in the Notaries (Post-Admission Supervision and Training) Rules 2019;
c. providing the Services, including, where applicable, procuring acts from foreign organisations;
d. 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;
e. allowing you to use features on our website, when you choose to do so;
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:
Cookies
11. 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.
12. Cookies can be first party or third party cookies:
Cookies on our website
13. We use the following cookies on our website:
We may combine information from these types of cookies and technologies with information about you from other sources.
Cookie consent
15. 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 then 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.
16. 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 then 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 www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
Disclosure of personal data
17. 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:
International transfer of your personal data
18. 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.
19. 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
20. 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.
21. 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
22. The Business will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.
23. 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
24. Data subjects have numerous rights in relation to their personal data:
25. For further information about your data protection rights please visit the ICO website.
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