Our full terms of business are provided upon engagement and form part of our client care letter. Please contact us to request a copy or for more information.

By instructing us you agree to be bound by our standard terms and conditions of business, which include provisions relating to fees, payment, confidentiality, data protection, and the professional rules applicable to notarial practice.

Our practice is regulated through the Faculty Office of the Archbishop of Canterbury. We are subject to the Notaries Practice Rules and all associated professional obligations.

Regulations and Complaints Procedures

1. My notarial practice is regulated through the Faculty Office of the Archbishop of Canterbury:

   The Faculty Office
   1, The Sanctuary
   Westminster
   London SW1P 3JT
   Telephone: 020 7222 5381
   Email: Faculty.office@1thesanctuary.com
   Website: www.facultyoffice.org.uk

2. If you are dissatisfied about the service you have received please do not hesitate to contact me.

3. If we are unable to resolve the matter you may then complain to the Notaries Society of which I am a member, who have a Complaints Procedure which is approved by the Faculty Office. This procedure is free to use and is designed to provide a quick resolution to any dispute.

4. In that case please write (but do not enclose any original documents) with full details of your complaint to:

   The Secretary of The Notaries Society
   P O Box 876
   Chichester PO19 9ZH
   Email: secretary@thenotariessociety.org.uk

   If you have any difficulty in making a complaint in writing please do not hesitate to call the Notaries Society or the Faculty Office for assistance.

5. Finally, even if you have your complaint considered under the Notaries Society Approved Complaints Procedure, you may at the end of that procedure, or after a period of 8 weeks from the date you first notified me that you were dissatisfied, make your complaint to the Legal Ombudsman, if you are not happy with the result:

   Legal Ombudsman
   P O Box 6167
   Slough SL1 0EH
   Tel: 0300 555 0333
   Email: enquiries@legalombudsman.org.uk
   Website: www.legalombudsman.org.uk

6. If you decide to make a complaint to the Legal Ombudsman, you must refer your matter to the Legal Ombudsman within one year from the act/omission or within one year from when you should reasonably have known there was cause for complaint.

ASTON-DIVE NOTARY & CO — DATA PROTECTION PRIVACY NOTICE

1. The business of ALENA ASTON-DIVE trading as ASTON-DIVE NOTARY & CO of Curlytail Bungalow, Adversane Lane, Adversane, Billingshurst, West Sussex RH14 9EG. ("Business", "we", "us", "our"). The Business is registered with the Information Commissioner's Office ("ICO") under number Z2796789.

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 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 paragraph 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. The Business may obtain information about you from third party service providers, such as due diligence platforms.

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.

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; (b) to the extent required, 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.

How Do We Use Your Personal Data?

10. The Business will only process personal data, in accordance with applicable law, for the following purposes:

    • Responding to your queries, requests and other communications;
    • Providing the Services, including procuring acts from foreign organisations;
    • Enabling suppliers and service providers to carry out certain functions on behalf of the Business;
    • Ensuring the security of the Business and preventing or detecting fraud;
    • Administering our Business, including complaints resolution and troubleshooting;
    • Developing and improving our Services;
    • Complying with applicable law, including Notary Practice Rules, guidelines and regulations.

Disclosure of Personal Data

11. There are circumstances where the Business may disclose your personal data to third parties, including: our subsidiaries or associated offices; our suppliers and service providers; public authorities to carry out acts necessary in connection with the Services; foreign organisations such as Embassies, Consulates and High Commissions; professional organisations such as The Notaries Society and the Faculty Office; successor or partner legal entities; and any other third party where you have provided your consent.

International Transfer of Your Personal Data

12. We may transfer your personal data to a third party in countries outside the country in which it was originally collected. In particular, your personal data may be transferred to foreign organisations such as foreign Embassies located in the UK or abroad.

13. If the Business transfers personal data to private organisations abroad, it will ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.

Retention of Personal Data

14. Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by law. The Notaries Practice Rules require 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.

15. We may keep an anonymized form of your personal data for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Security of Personal Data

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

17. 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 cannot therefore guarantee the security of your information transmitted to us on the web.

Data Subject Rights

18. Data subjects have numerous rights in relation to their personal data. For further information about your data protection rights please visit the ICO website. Your rights include:

    • Right to make a subject access request (SAR) — you may request copies of your personal data.
    • Right to rectification — you may request that we rectify any inaccurate or incomplete personal data.
    • Right to withdraw consent — you may at any time withdraw your consent to the processing of your personal data.
    • Right to object to processing — including automated processing and profiling.
    • Right to erasure — you may request that we erase your personal data, subject to lawful exceptions.
    • Right to restriction — you may request that we restrict our processing of your personal data in various circumstances.
    • Right to data portability — in certain circumstances, you may request a copy of your personal data in a structured, commonly used and machine-readable format.
    • Right to lodge a complaint — you have the right to contact the relevant supervisory authority directly.

In order that you as a service provider and data processor ("Processor") may provide or continue to provide certain services ("Services") to us, the Notary Business and data controller ("Notary Business"), you have agreed that these data processing terms ("Terms") shall apply in order to address the compliance obligations imposed pursuant to Data Protection Law.

BY ACCEPTING ANY MATERIALS FROM THE NOTARY BUSINESS OR OTHERWISE COMMENCING THE SERVICES ("EFFECTIVE DATE"), YOU AGREE THAT THE PROCESSOR WILL PROCESS NOTARY BUSINESS PERSONAL DATA IN ACCORDANCE WITH THESE TERMS.

Definitions

• "Affiliate" means any entity that directly or indirectly controls, is controlled by, or is under common control with, a party;
• "Data Protection Law" means the data privacy laws applicable to the processing, including the GDPR or similar law, or the applicable data privacy laws of any other relevant jurisdiction;
• "Client" means any client of the Notary Business;
• "Contractual Clauses" means the standard contractual clauses of the European Commission for the transfer of personal data across borders;
• "Notary Business Personal Data" means the personal data processed by Processor in connection with the Services on behalf of the Notary Business.

Appointment

Processor is appointed by Notary Business to process Notary Business Personal Data on behalf of the Notary Business and/or the Instructing Parties, as the case may be, as is necessary to provide the Services or as otherwise agreed by the parties in writing.

Duration

The Terms shall commence on the Effective Date and shall continue in full force and effect until such time as all Services have ceased and all Notary Business Personal Data in the Processor's possession has been returned or destroyed.

Data Protection Compliance

In relation to its processing of Notary Business Personal Data, save as otherwise required by law, Processor agrees to:

1. Process Notary Business Personal Data only as required in connection with the Services and in accordance with our documented lawful instructions;
2. Inform us if, in your opinion, an instruction infringes Data Protection Law;
3. Ensure that all personnel authorised to process Notary Business Personal Data have committed themselves to confidentiality;
4. Implement appropriate technical and organisational measures to safeguard Notary Business Personal Data;
5. Promptly inform us of any data subject requests or regulatory requests relating to Notary Business Personal Data;
6. Provide assistance as reasonably required for compliance with Data Protection Law;
7. At our choice, delete or return all Notary Business Personal Data; and
8. Make available information reasonably necessary to demonstrate compliance with these Terms.

Subprocessors

Processor will sub-contract or engage Subprocessors only with Notary Business's prior written consent. When engaging a Subprocessor, Processor will carry out reasonable due diligence, enter into a contract on terms equivalent to these Terms, and inform us of any intended changes.

Security Incidents

Processor will notify the Notary Business without undue delay if Processor becomes aware of any Security Breach (being a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of, or access to, Notary Business Personal Data).

International Data Transfers

Processor will ensure that no Notary Business Personal Data are transferred outside the European Economic Area, or any other territory where data transfer restrictions apply, without the prior written consent of Notary Business and subject to Contractual Clauses or other applicable transfer mechanism being in place.

Indemnity

Processor shall indemnify Notary Business and Instructing Parties from and against any claims, losses, demands, actions, liabilities, fines, penalties, reasonable expenses, damages and settlement amounts incurred as a result of any gross negligence or wilful breach by Processor of these Terms.

Miscellaneous

These Terms are governed by English law and the parties submit to the exclusive jurisdiction of the English courts in relation to any dispute concerning these Terms.

Schedule: Security Measures

Minimum Technical Measures

• Firewalls which are properly configured and using the latest software
• User access control management
• Unique passwords of sufficient complexity and regular expiry on all devices
• Secure configuration on all devices
• Regular software updates
• Real-time protection anti-virus, anti-malware and anti-spyware software
• HTTPS
• Encryption of all portable devices
• Encryption of personal data in transit
• Multi-factor authentication for remote access
• Intrusion detection and prevention systems
• Data backup and disaster recovery measures and procedures

Minimum Organisational Measures

• Vet all personnel including staff, contractors, vendors and suppliers on a continuous basis
• Non-disclosure agreements used with all personnel
• Regular training of all personnel on confidentiality and data processing obligations
• Apply principle of least authority
• Physical security on premises including reception, security passes, clean desk policy, secure disposal of materials
• Apply appropriate policies including Information Security Policy, Data Protection Policy, Acceptable Use Policy