Data Protection Privacy Policy

(Updated July 2022)

1. The business of Steven Wignall Legal Services Ltd (t/a Steven Wignall, Notary Public) of No. 1
St Paul’s Square, Liverpool, L3 9SJ (“Business”, “we”, “us”, “our”). The Business is registered
with the Information Commissioner’s Office (“ICO”) under Registration reference ZA336906.
2. If you have any questions about this privacy notice (“Notice”), please contact us by e-mail at
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 notification of 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 8.
What is Personal Data?
6. “Personal data” means any information relating to an identified or identifiable natural person,
known as a ‘data subject’, who can be identified directly or indirectly; it may include name,
address, e-mail 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
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 obligatory 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 lead to some other difficulty in 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 that 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
(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) allowing you to use features on our 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 the Cookie Statement below. You have the right to disable cookies as set
out below;
(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 the 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.
Cookie statement
What exactly are 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.
• 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.
The cookies placed on our website
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
• 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.
• 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.
• Targeting or advertising cookies. 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.
• 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.
14. We may combine information from these types of cookies and technologies with information
about you from other sources.
Cookie consent and opting out
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, 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,
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
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:
• our subsidiaries or associated offices;
• our suppliers and service providers to facilitate the provision of the Services, including
couriers, translators, the solicitors’ practice of Hill Dickinson LLP (with whom we share
premises and reception and other staff), IT consultants and legalisation and other handling
agents, webhosting providers, identity verification partners (in order to verify your identity
against public databases) and consultants, for example, in order to protect the security or
integrity of our business, including our databases and systems and for business continuity
• public authorities to carry out acts which are necessary in connection with the Services,
such as the Foreign & Commonwealth 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;
• subject to your consent, our advertising and marketing partners who enable us, for
example, to deliver personalised ads to your devices or who may contact you by post, email, telephone, SMS or by other means;
• 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
18. We may transfer your personal data to a third party in countries outside the country in which it
was originally collected, including countries outside the EU, 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
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 anonymised 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 e-mail, 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. 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
• 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.
• 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 archiving obligations
that we have to comply with.
• Restriction. Data subjects may request that we restrict 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. Data subjects should
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