Legal

Overseas data processing notice.

Most research happens in India. This notice explains what we transfer, to whom, why, and the safeguards we put in place.

Draft — pending solicitor review

This Overseas Data Processing notice is a structural draft. The detailed legal wording is being prepared by our solicitor and will replace the placeholder sections below. Until then, please contact us with any specific questions and do not rely on this document for legal interpretation.

Last updated: TODO.

1. Summary

Some information you submit is shared with our field researchers in India and the hereditary priests who hold the relevant bahi register, so that the search can be carried out. We share only what is necessary for the search.

2. What we transfer and why

We transfer only the minimum needed for each step:

  • To researchers: surnames, ancestral village/district/state, names and approximate dates for the family members you have asked us to look up, plus any photos or audio recordings you have uploaded.
  • To hereditary priests: the subset of the above necessary to locate your family's pages. We do not share your payment data, your home address, or other UK identity details.

3. Safeguards we apply

To be added by client: UK GDPR Article 46 safeguards: Standard Contractual Clauses (UK Addendum / UK IDTA), confidentiality undertakings from researchers, named-priest arrangements, secure transfer channels, no retention by priests beyond the lookup.

4. Basis for the transfer

To be added by client: Article 49 derogation (necessary for performance of the contract with the data subject) as primary basis where applicable; supplemented by SCCs/IDTA. Explain to the customer in plain English.

5. Your rights

You may ask us to stop transferring your data to any specific researcher or priest at any time. Note that doing so may make fulfilling the service impossible — see our Search & Refund Policy for the refund treatment in that case.

6. Contact and complaints

For questions about overseas transfers, contact us. You may also complain to the UK Information Commissioner's Office (ico.org.uk).