Privacy Policy

1. Introduction

We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

As a property investment trust, we handle sensitive financial and personal information. We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

We may collect and process the following types of information:

Personal Information

• Name, email address, phone number, and postal address
• Company name and position (for business contacts)
• Financial information relevant to investment opportunities
• Identification documents for due diligence purposes
• Communication preferences and correspondence history

Technical Information

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on our website
• Referring website addresses
• Cookies and similar tracking technologies

Investment-Related Information

• Investment preferences and criteria
• Property or business interests
• Financial capacity and investment history
• Due diligence documentation

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To provide information about investment opportunities and property acquisitions
• Communication: To respond to inquiries, send updates, and maintain business relationships
• Due Diligence: To conduct necessary checks and comply with legal obligations
• Website Improvement: To analyze usage patterns and enhance user experience
• Legal Compliance: To meet regulatory requirements and prevent fraud
• Marketing: To send relevant information about our services (with your consent)

4. Legal Basis for Processing

Under UK GDPR, we process your personal data based on the following legal grounds:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal Obligation: Processing is necessary for us to comply with the law (such as anti-money laundering regulations)
• Legitimate Interests: Processing is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not overridden by your rights

5. Information Sharing and Disclosure

We may share your information with:

• Professional Advisors: Lawyers, accountants, and financial advisors who assist with transactions
• Service Providers: Third-party companies that help us operate our business (e.g., IT services, marketing platforms)
• Regulatory Bodies: Government agencies and regulators when required by law
• Business Partners: Other parties involved in property or corporate transactions (with your consent)
• Legal Requirements: When disclosure is necessary to comply with legal obligations or protect our rights

We do not sell your personal information to third parties. All third parties we work with are required to maintain the confidentiality and security of your information.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection and security
• Secure backup and disaster recovery procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary depending on the type of information and the purpose for which it was collected:

• Transaction Records: Retained for at least 7 years for tax and legal purposes
• Marketing Communications: Retained until you withdraw consent or we determine the information is no longer needed
• Website Analytics: Typically retained for 26 months
• Due Diligence Documents: Retained in accordance with anti-money laundering regulations

8. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data to another organization
• Right to Object: Object to processing of your personal data in certain circumstances
• Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing

To exercise any of these rights, please contact us using the information provided at the end of this policy. We will respond to your request within one month.

9. International Data Transfers

Your information may be transferred to and processed in countries outside the UK. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the UK authorities
• Transfers to countries with adequate data protection laws
• Other legally approved transfer mechanisms

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us through the contact information provided on our website.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.