Furthermore, 
        Intelligent Sanctuary representatives must not solicit, request, agree to receive or accept, directly or indirectly, any financial or other advantage or anything of value that is (or may appear to be) related to inducing or rewarding improper performance by any Intelligent Sanctuary representative of any function or activity. Bribes paid through a third party:Intelligent Sanctuary Ltd. representatives must <br />not:(i) make; or <br />(ii) offer or promise to make; or <br />(iii) authorise or procure anyone to make: any payment or gift of money or anything of value, or gift or conveyance of any financial or other advantage, either directly or indirectly, to a third party if they know or suspect that it will be offered to or for the benefit of any person (including a Public Official whether “domestic” or “foreign”) and that it will be (or may appear to be) inducing, securing, or rewarding the improper performance by any person of any function or activity (whether or not it will be done to obtain or retain business or a business advantage). Helping or allowing others to give or receive bribes: Intelligent Sanctuary representatives must not consent to, or connive in, aid or abet, counsel or procure the commission of any of the above. Intelligent Sanctuary representatives must not conspire with, aid or abet, counsel or procure any third party in the contravention of any applicable anti-corruption laws. Internal controls: Intelligent Sanctuary Ltd.:<ul><li>Maintains a reasonable system of internal controls to prevent any improper or corrupt payments; and</li><li>Ensures that all financial transactions are accurately and fairly recorded in that practice's books and records.</li></ul>

The receipt of bribes

Intelligent Sanctuary representatives who contravene any applicable anti-corruption laws may expose Intelligent Sanctuary and themselves to significant criminal and/or civil sanctions. A failure to act in accordance with the letter and spirit of applicable anti-corruption laws and Intelligent Sanctuary Anti-Corruption Policy may result in disciplinary or other action by Intelligent Sanctuary against the persons concerned. Such failure may also be reportable to and/or give rise to disciplinary action by professional bodies regulating the Intelligent Sanctuary representative. Anti-Corruption Laws: Because Intelligent Sanctuary Ltd. is an internationally focused law firm, Intelligent Sanctuary representatives must comply with the domestic anti-corruption laws of many different countries. In some countries, the anti-corruption laws have global application (for example, the US Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act 2010 (the “Bribery Act”). The primary focus of these laws is to prohibit improper inducements to “foreign” Public Officials or in connection with international business transactions. However, the laws of many countries also prohibit the bribery of “domestic” Public Officials. Moreover, numerous countries have adopted “commercial” bribery laws which, in essence, prohibit the offering, promising, or giving to persons in the private sector of any inducements or reward for the improper performance of any function or activity. The request for, agreement to receive, or acceptance of any such inducement or reward is also prohibited. Specifically, the FCPA and the Bribery Act have wide territorial application but they are not unique in operating on an extraterritorial basis. Pursuant to the Bribery Act, all UK citizens, persons who are ordinarily resident in the UK as well as companies and partnerships which are incorporated or formed in the UK, may be prosecuted in the UK for bribery offences, even if those offences were committed wholly outside the United Kingdom. Furthermore, if Intelligent Sanctuary representatives commit a bribery offence anywhere in the world, Intelligent Sanctuary directors may be prosecuted in the UK courts for failing to prevent that bribery from occurring. All US citizens are subject to prosecution under the FCPA, even if the bribery offence occurred entirely outside the United States. The nationals of other countries may also be prosecuted under the FCPA if the conduct amounting to the bribery offence has a connection with the United States. Under US law, any Intelligent Sanctuary representative who commits a bribery offence contrary to the FCPA will also expose Intelligent Sanctuary to the risk of prosecution. Intelligent Sanctuary representatives are not expected to become experts in the anti-corruption laws applicable to them. They should, however, be aware of the circumstances when corruption concerns may arise as a result of anti-corruption laws of their own and other jurisdictions and adjust their behaviour accordingly. If in doubt, they should seek guidance from Intelligent Sanctuary directly.

Effect of failure to comply

Intelligent 
        Sanctuary Ltd. may carry out a risk assessment identifying and prioritising anti-corruption risks. This includes an evaluation of the jurisdictions in which Intelligent Sanctuary operates, the markets for its particular services, the extent to which it uses third parties to act on its behalf, and the degree of interaction with Public Officials. Intelligent Sanctuary will develop its policies and procedures based on its evaluation of those risks, which shall be approved by the Partners. Education and Training: Intelligent Sanctuary Ltd. implements and maintains a program to provide regular anti-corruption education and training to its partners and staff. Questions: any questions about this Policy should be raised with Intelligent Sanctuary Ltd. Endnotes: “Public Official” for the purposes of this Policy includes:(a) all officials, employees, agents, and representatives of any branch or level of government (executive, legislative or judicial and whether national, state or local) or of any government department or agency (including advisers to such agencies and branches); (b) directors, officers, and employees of State-owned or controlled companies (including their consultants, advisers, agents and other representatives); (c) political parties, party officials, and candidates for office; (d) officials and employees of public international organisations such as the World Bank, European Union, or the United Nations (including their consultants, advisers, agents and other representatives); and (e) any other person who, by reason of domestic law in any jurisdiction in which the Firm may operate, would be considered or deemed a Public Official. The terms “anything of value” and “financial or other advantage” are to be construed broadly. They include not only cash but also gifts, gift cards, items bearing logos and other tangible items, electronic equipment, clothing, meals, entertainment (for example, concert, theatre, sport, or other similar event invitations without a prevailing business character), travel, lodging, transportation, loans, use of property or equipment, charitable contributions, and job offers. The “performance” or “failure” to perform any function or activity is “improper” if it breaches the expectations of good faith or impartiality or breaches a position of trust. Additionally, in certain Asian jurisdictions, it is “improper” if the performance of a function or activity (even if done properly) has been brought about by the payment, gift, or offer of financial or other advantage that was made without lawful authority or reasonable excuse. The term “function or activity” includes a function of a public nature or an activity connected with a business or performed in the course of employment by or on behalf of a body of persons and the person performing the function or activity is expected to perform it in good faith and impartially or is in a position of trust by virtue of performing it. This prohibition includes, but is not limited to, offering, paying, promising to pay, or authorising the payment of anything of value to any Public Official directly, or indirectly through another person, to influence any act or decision of the Public Official in the Public Official's official capacity, to induce the Public Official to do or omit to do any act in violation of the lawful duty of the Public Official, to secure any improper advantage, or to induce the Public Official to influence any act or decision of a government or government instrumentality, in order to obtain or retain business for, or direct business to, any person.

Risk Assessment and Procedures

Intelligent Sanctuary Ltd. does not tolerate any form of bribery or corruption and it is a requirement of this Policy that all Intelligent Sanctuary representatives, (including consultants and sub-contractors) comply with both the letter and the spirit of this Policy and all applicable anti-corruption laws. The giving of bribes: Intelligent Sanctuary Ltd. representatives must not:<br />(i) make; or <br/>(ii) offer or promise to make; or <br/>(iii) authorise or procure anyone to make: any payment or gift of money or anything of value, or gift or conveyance of any financial or other advantage, either directly or indirectly, to or for the benefit of any person (including a Public Official whether “domestic” or “foreign”) that is (or may appear to be) inducing, securing, or rewarding the improper performance by any person of any function or activity (whether or not it was done to obtain or retain business or a business advantage).

Anti-corruption Policy

Intelligent 
    Sanctuary Ltd (hereafter 'the company') is a London-based company and at all times remains subject to all extant laws of the United Kingdom, European Union any other jurisdiction in which we operate. The company is subject to GDPR, Privacy laws, the FCPA and Bribery Act and will conduct diligence on all potential, new and existing clients to remain compliant with legislation. The company conducts inquiries into people, companies and other entities only when legitimate interest is satisfied. Where applicable the client must demonstrate legitimate interest exists or persons, companies and other legal entities consent to inquiries into their personal information and that the company acts under privilege. The company will identify, collect and analyse personal information when investigating a crime, suspected crime, civil dispute or potential civil dispute or when consent is provided. The company identifies, accesses, stores and disposes of personal information in accordance with GDPR. All projects, inquiries, actions or instructions undertaken by the company require the client to be the data controller and the company is the data processor in accordance with GDPR.  The company will not retain personal information beyond 30 days after a project, inquiry, action or instruction is complete. The company will only retain personal information when instructed to do so by the client for the purpose of ongoing legal proceedings or future legal proceedings and only when the company is satisfied it is proportionate and legitimate to retain the personal information. The company will notify the client in writing thirty days before deleting personal information relevant to the engagement. All personal information held by the company for the project, inquiry, action or instruction will, as the data processor, pass to the client as the data controller.

Ethics, compliance and diversity

<h3 class="my-4">
        Information collection</h3>We may collect the following information: name and job title; contact information including email address; demographic information such as postcode, preferences and interests; other information relevant to customer surveys and/or offers. We do not send any promotional emails; however, we may send you marketing emails related to your subscriptions. If you no longer wish to receive these emails, you may opt out of them by updating your preferences in our marketing emails or contact us at <a href='mailto:info@isanctuary.io'>info@isanctuary.io</a><h3 class="my-4">Intended use of personal data</h3>Most of our services do not require any form of registration, allowing you to visit our site without telling us who you are. However, some services may require you to provide us with personal data. We require this information to understand your needs and provide you with a better service and, in particular, for the following reasons: internal record keeping; to improve our products and services; to periodically send marketing emails about new products, special offers or other information which we think you may find interesting, using the email address which you have provided. From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests. However, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your query.

Information collection and use

<h3 class="my-4">
        Access to information</h3>You have the right to request access to the information we have on you. You can do this by contacting us at <a href='mailto:info@isanctuary.io'>info@isanctuary.io</a>. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent request, we may charge you a small fee. <h3 class="my-4">Information correction and deletion</h3>If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for the purposes specified in Information collection and Use will be deleted. If at any point you want Intelligent Sanctuary to delete information about you, you can simply contact us.

Your individual rights

You may choose to restrict the collection or use of your personal information in the following ways:<p class="my-2">Whenever you are asked to fill in a form on the website, look for the box you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes; if you have previously agreed to us using your personal information for direct marketing purposes, you can change your mind at any time by writing to or emailing us at <a href=`mailto:info@isanctuary.io`>info@isanctuary.io</a>. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.</p><h3 class="my-4">How we share your information</h3><p class="my-2">Intelligent Sanctuary will not rent, sell or distribute your personally identifiable information to third parties unless we have your permission or are required by law to do so. We may store personal data in locations outside the direct control of Intelligent Sanctuary (for instance on servers or databases of data processors) which we have ensured are GDPR compliant. Additionally, any personally identifiable information you elect to make publicly available on our site, such as posting comments on our blog page, will be available to others.</p><h3 class="my-4">Storage and processing</h3><p class="my-2">Your information collected through our website and services may be stored and processed in Europe, the United States, or any other country in which Intelligent Sanctuary or its subsidiaries, affiliates or service providers maintain facilities.</p><h3 class="my-4">Links to other sites</h3><p class="my-2">Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we have no control over other websites. We cannot therefore be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.</p><h3 class="my-4">International privacy laws</h3><p class="my-2">We will not transfer your data internationally, except if it is a legal obligation and/or for honouring a contractual agreement. We have ensured that data processors are compliant to the EU-US Privacy Shield as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from European Union countries. The data processors have certified that they adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity &amp; Purpose Limitation, Access and Recourse, Enforcement &amp; Liability when processing Personal Data from the EEA in the United States.</p>

Controlling your personal information

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Security

<p class="my-2">
        You can contact us at any time to:</p><ul class="list-disc"><li>Request access to information that Intelligent Sanctuary has about you</li><li>Correct any information that Intelligent Sanctuary has about you</li><li>Delete information that Intelligent Sanctuary has about you</li></ul><p class="my-4">If you have any additional questions about Intelligent Sanctuary's collection and storage of data, please contact us:</p><p class="my-2">2a Claridge Court,<br />Lower Kings Road, Berkhamsted<br>HP4 2AF</p><p class="my-2">via phone <a href='tel:+442038712529'>+44 203 871 2529</a> or via email: <a href='mailto:info@isanctuary.io'>info@isanctuary.io</a></p><p class="my-2"><br />Intelligent Sanctuary uses browser cookies to give you the best possible experience. By
        using <a href='http://www.isanctuary.io/'>www.isanctuary.io</a> you agree to our Privacy Policy. you agree to our Privacy Policy.</p>

Questions

This privacy policy sets out how Intelligent Sanctuary Ltd.  uses and protects any information that you provide when you use this website. Intelligent Sanctuary Ltd.  is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. Intelligent Sanctuary Ltd.  may change this policy from time to time by updating this page. You should check this page for the most current version. This policy is effective from 26/04/2021.

Privacy Policy

Welcome to our website. If you continue to browse and use this website you are agreeing to comply
    with and be bound by the following terms and conditions of use which, together with our privacy
    policy, govern Intelligent Sanctuary Ltd's relationship with you in relation to this website. If you
    disagree with any part of these terms and conditions, please do not use our website.
    <br />
    <br />
    
    The term &#39;Intelligent Sanctuary Ltd.&#39; or ‘iSanctuary.&#39; or &#39;ISL&#39; or &#39;us&#39; or &#39;we&#39; or &#39;our&#39; refers to the owner
    of the website whose registered office is Intelligent Sanctuary Ltd., 2a Claridge Court, Lower Kings
    Road, Berkhamsted, HP4 2AF. Our Information Commissioner&#39;s Office registration number is:
    ZA554572
    <br />
    <br />

    The use of this website is subject to the following terms of use:<br /><br />
    <ul>
        <li>The content of the pages of this website are for your general information and use only. It is subject to change without notice.</li>
        <li>Nothing in these pages constitutes legal advice. You should consult a suitably qualified
        lawyer on any specific legal problem or matter.</li>
        <li>Neither we nor any third parties provide any warranty or guarantee as to the accuracy,
        timeliness, performance, completeness or suitability of the information and materials found
        or offered on this website for any particular purpose. You acknowledge that such
        information and materials may contain inaccuracies or errors and we expressly exclude
        liability for any such inaccuracies or errors to the fullest extent permitted by law.</li>
        <li>Your use of any information or materials on this website is entirely at your own risk, for
        which we shall not be liable. It shall be your own responsibility to ensure that any products,
        services or information available through this website meet your specific requirements.</li>
        <li>This website contains material which is owned by or licensed to us. This material includes,
        but is not limited to, the design, layout, look, appearance and graphics. Reproduction is
        prohibited other than in accordance with the copyright notice which forms part of these
        terms and conditions.</li>
        <li>All trademarks reproduced in this website which are not the property of, or licensed to, the
        operator, are acknowledged on the website.</li>
        <li>Unauthorised use of this website may give rise to a claim for damages and/or be a criminal
        offence.</li>
        <li>From time to time, this website may also include links to other websites. These links are
        provided for your convenience to provide further information. They do not signify that we
        endorse the website(s). We have no responsibility for the content of the linked website(s).
        <li>Your use of this website and any dispute arising out of such use of the website is subject to
        the laws of England, Northern Ireland, Scotland and Wales.</li>
        </ul>

Terms and Conditions

This Cookie Policy explains how our website uses cookies and similar technologies to enhance your browsing experience and analyze website traffic. By using our website, you consent to the use of cookies as described in this policy.
    <br/><br />1. What are cookies?<br /><br />
    Cookies are small text files that are stored on your device (computer, tablet, or mobile) when you visit a website. They are widely used to make websites work or improve their efficiency, as well as to provide information to the website owners.
    <br/><br />2. How we use cookies<br /><br />
    Our website uses cookies for the sole purpose of collecting statistical information through Google Analytics. These cookies help us analyze website traffic and improve our website's performance, design, and content. They do not collect any personally identifiable information about you.
    The cookies used on our website may include:
    <ul>
    <li>Performance cookies: These cookies help us monitor the performance of our website, including the number of visitors, the pages visited, and any errors that may occur. They allow us to analyze and improve the functionality and effectiveness of our website.</li>
    <li>Analytics cookies: We use Google Analytics to track and analyze anonymous usage information, such as the number of visitors to our website, the pages visited, and the duration of their stay. This information helps us understand user preferences and optimize our website content accordingly.</li>
    </ul>
    3. Third-party cookies<br /><br />
    We do not use any third-party cookies on our website. However, please note that third-party services, such as Google Analytics, may set their own cookies to provide the services they offer. These cookies are governed by the respective privacy policies of these third-party service providers.
    <br /><br />4. Cookie management<br /><br />
    By continuing to use our website, you consent to the use of cookies as described in this policy. However, if you wish to control or delete cookies, you can do so through your browser settings. Please note that disabling cookies may impact your browsing experience or prevent certain features from functioning properly.
    To learn more about how to manage cookies in your browser, please visit the appropriate link below:
    <ul>
    <li><a href="https://support.google.com/chrome/answer/95647" target="_blank">Google Chrome</a></li>
    <li><a href="https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences" target="_blank">Mozilla Firefox</a></li>
    <li><a href="https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d" target="_blank">Microsoft Edge</a></li>
    <li><a href="https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac" target="_blank">Safari</a></li>
    </ul>
    <br /><br />5. Updates to this policy<br /><br />
    We may update this Cookie Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be effective upon posting the revised policy on our website. We encourage you to periodically review this page for the latest information on our use of cookies.
    <br /><br />6. Contact us<br /><br />
    If you have any questions or concerns about our Cookie Policy or our use of cookies, please contact us at <a href='mailto:info@isanctuary.io'>info@isanctuary.io</a>.
    Please note that this Cookie Policy should be read in conjunction with our Privacy Policy, which provides more detailed information about how we collect, use, and protect your personal data.
    By using our website, you agree to our use of cookies as described in this policy.

Legal

Privacy Policy

Information collection and use

Your individual rights

Controlling your personal information

Security

Questions

Anti-corruption Policy

The receipt of bribes

Effect of failure to comply

Risk Assessment and Procedures

Ethics, compliance and diversity

Privacy Policy

Information collection and use

Your individual rights

Controlling your personal information

Security

Questions

Terms and Conditions

Cookies Policy