Privacy Policy

Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your property investment and management requirements and, in some cases, your financial situation (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, tax identification number etc. Your Personal Data may also identify you indirectly, for example, your employment situation, your tax residence, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your property investment, property management, finance and business consultancy, your Personal Data may include:

Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
Employment and remuneration information, (including salary and business profit),
Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents

The basis upon which our Company will deal with Your Personal Data

When we speak with you about your property investment, property management, finance and business, we do so on the basis that both parties are entering a contract for the supply of services as specified on our client agreement.

To perform that contract, we have the right to use Your Personal Data for this purpose.

Alternatively, either during our initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from your bank, solicitors, estate agents, financial providers and advisers or HM Revenue & Customs.

On occasion, we will use Your Personal data for contractual responsibilities, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information to manage your business consultancy, property investment, management and finance needs. You will provide information to us verbally and in writing, including electronically.

What happens to Your Personal Data when it is disclosed to us?

During handling Your Personal Data, we will:

Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Company and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
Submit Your Personal Data to Banks, Estate Agents, Auctioneers, Developers and other third parties as necessary, both in paper form and on-line via a secure portal.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to your business consultancy, property investment, management and finance needs.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with third parties who we believe can support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, banks and investment providers, estate agents, providers of legal services, specialists such as estate planners, financial advisers, accountants, insurance companies, surveyors and valuers. (in each case where we believe this to be required due to your circumstances).

If the law allows or requires us to do so, we may share your personal data with:

the police and law enforcement agencies
courts and tribunals
the Information Commissioner’s Office (“ICO”)

In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress with and to provide you with our professional services.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.

Your rights in relation to Your Personal Data

You can:

request copies of Your Personal Data that is under our control
ask us to further explain how we use Your Personal Data
ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Personal Data to another organisation should you wish
change the basis of any consent you may have provided to enable us to share your personal data in the future (including withdrawing any consent in its entirety)

How to contact our Company in relation to the use of Your Personal Data

If you have any questions or comments about this document or wish to make contact to exercise any of your rights set out within it, please contact Hiren Shah on 020 8931 1555 or write to us.

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time. You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Email Disclaimer

Any e-mail and any attachments received are confidential. They are intended only for the person to whom they are addressed to and/or otherwise authorised personnel. If you are not the intended recipient, please be advised that viewing the message and any attachments, as well as copying, forwarding, printing, and disseminating any information related to the email is prohibited, and that you should not take any action based on the content of the email and/or its attachments. If you have received the message in error, please immediately contact the sender and destroy all copies of the email and any attachment from your computer. The contents of any attachment to the e-mail may contain software viruses, which could damage your own computer system. No warranties or assurances are made in relation to the safety and content of the email and attachments. While we have taken every reasonable precaution to minimise this risk, we cannot accept liability for any damage which you sustain as a result of software viruses. You should carry out your own virus checks before opening the attachment. No liability is accepted for any consequences arising from the email.

Effective date: 25 May 2018