1. The business of ANDREEA BOSTAN – NOTARY PUBLIC of 106 Old Christchurch Road, Bournemouth, BH1 1LR trading as ANDREEA BOSTAN (“Business”, “we”, “us”, “our”). The Business is registered with the Information Commissioner’s Office (“ICO”) under number ZA189447.

2. If you have any questions about this privacy notice (“Notice”), please contact us by email.

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 (“Services”).

4. We will let you know by posting on our website 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 & 9.

What is 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 do we use your 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) 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) ensuring the security of the Business and preventing or detecting fraud;
(e) administering our Business, including complaints resolution, troubleshooting of our website, data analysis, testing of new features, research, statistical and survey purposes;
(f) developing and improving our Services;
(g) 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.


What exactly are cookies?

11. 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.

• 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.

13. We use the following cookies on our website:

• 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.

14. We may combine information from these types of cookies and technologies with information about you from other sources.

15. CALL RECORDING:

Your consent to call recording

15.1 We may record telephone conversations. When you call us, we will play a short message informing you about call recording, where applicable. You will need to follow the instructions as to whether you consent to having your call recorded or not.

15.2 We may record your calls with us for the following purposes:

(a) establishing the existence of facts relevant to our business, including a record of your instructions, orders, complaints or other communications;
(b) reviewing how we and our personnel comply with our regulatory and legal obligations;
(c) quality control and staff training;
(d) preventing and detecting crime;
(e) ensuring the effective operation of our communication systems and detecting and preventing unauthorised use; and
(f) as otherwise permitted by law.

16.Call recording consent and opting out

16.1 . We assume that you are happy for us to record your calls. However, if you wish to withdraw your consent at any time, you have the ability to accept or decline. If you choose to decline call recording, at the prompter, please hung up and use an alternative method of contact. You may not be able to fully experience the interactive features of our services.

17. Records of calls are kept as follows:

17.1 All calls relating to notarial transactions shall be kept indefinitely.

17.2 All other calls shall be kept for a minimum of 6 years.

17.3. When you call our office a message will plat asking for your consent to record calls. In order to provide your consent, please continue with the call. Once your consent has been provided, you can then continue with the call.

Cookie consent and opting out

18.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.

19. When you arrive on our website there will not be pop-up message asking for your consent as we do not use cookies other than for functionality. If you continue using our website you provide your consent, If you do not consent, please close the website and contact us using another method. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by closing your browser. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.

20. CCTV Surveillance

We operate CCTV surveillance systems at our office premises to protect the safety and security of our employees, clients, visitors, contractors, business assets and premises; to prevent and detect crime, fraud, misconduct and unauthorised access; to investigate incidents and complaints, and, where applicable, for compliance with legal obligations and to establish, exercise or defend legal claims. CCTV footage may record employees, clients, visitors and other individuals attending our premises. Our lawful basis for processing personal data through CCTV is our legitimate interests in protecting our business, personnel, clients, property and legal rights.

CCTV recordings may be reviewed where necessary to investigate disputes, complaints, incidents, suspected misconduct, health and safety matters, security breaches, criminal activity, or where evidence is required in connection with legal proceedings. Footage may be disclosed to law enforcement agencies, insurers, legal advisers, courts, regulatory authorities or other authorised third parties where required or permitted by law.

CCTV recordings are accessible only to authorised personnel and may be disclosed to law enforcement agencies, insurers, legal advisers, regulatory authorities, or other parties where required or permitted by law.

Footage is retained only for as long as reasonably necessary for the purposes for which it was collected, after which it is securely deleted or overwritten, unless it is required for an investigation or legal proceedings. CCTV signage is displayed at relevant locations to inform individuals that monitoring is taking place.

Individuals have rights in relation to their personal data, including the right to request access to CCTV images of themselves, subject to applicable legal exemptions and the rights of other individuals.

21. 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:

• 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, governance and archiving functions in relation to the notaries profession, such as Chambers of Commerce, The Notaries Society and the Faculty Office;
• 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 data

22. 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.

23. 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

24. 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.

25. 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

26. The Business will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.

27. 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

28. Data 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 applicable.
• 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.
• Right to object to processing, including automated processing and profiling. The Business does not make automated decisions. 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 with.
• 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 UK or other relevant supervisory authority directly.

29. Complaints Procedure.

• We are committed to protecting personal data. We take all complaints regarding the handling of personal data seriously. This policy sets out our procedure for managing complaints.
• A complaint is any expression of dissatisfaction regarding how we have handled personal data, including Insecure data handling, failure to meet data protection rights (e.g., Subject Access Requests) or unfair or unlawful processing
• Individuals can make a complaint by emailing andreea@bostico.co.uk or by writing to me/us at 106 Old Christchurch Road, Bournemouth, BH1 1LR Please include: Your name, contact details, and full details of the complaint.
• We will acknowledge receipt of your complaint within 30 days. The complaint will be investigated by me/us. A substantive response will be provided without undue delay.
• We will keep records of all data protection complaints, including the nature of the complaint and the actions taken, to help improve our services.
• If you are dissatisfied with our response, you have the right to complain directly to the Information Commissioner’s Office (ICO), the UK’s supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.