Privacy Policy

HERITAGE PROPERTY PARTNERS LTD

Company Number: 15857766

Registered Office: 21 Downland Way, Durrington, Salisbury, England, SP4 8BX

Email: [email protected]

ICO Registration Number: ZB734355

Last Updated: 08/12/25

1. Introduction

HERITAGE PROPERTY PARTNERS LTD ("we", "us", "our", "the Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our property sourcing and packaging services.

We are registered with the Information Commissioner's Office (ICO) under registration number ZB734355 and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For the purposes of data protection law, HERITAGE PROPERTY PARTNERS LTD is the "data controller" of your personal information. This means we determine how and why your data is processed.

Important: Please read this Privacy Policy carefully. By using our services or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

Data Controller: HERITAGE PROPERTY PARTNERS LTD

Company Number: 15857766

Registered Office: 21 Downland Way, Durrington, Salisbury, England, SP4 8BX

Email: [email protected]

ICO Registration: ZB734355

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details above.

3. What Data We Collect

We collect and process various types of personal data depending on your relationship with us and the services we provide. The categories of personal data we may collect include:

3.1 Identity and Contact Information

- Full name, title, date of birth

- Home address and correspondence address

- Email address

- Telephone number(s) (mobile and landline)

- Proof of identity documents (passport, driving licence)

- Proof of address documents (utility bills, bank statements)

3.2 Financial Information

- Income and employment details

- Assets and liabilities

- Bank account details (for payment processing)

- Credit history or credit score (where relevant)

- Source of funds and source of wealth information

- Investment portfolio or property holdings

3.3 Property Investment Information

- Property investment criteria and preferences

- Investment objectives and risk tolerance

- Previous property investment experience

- Budget and financial capacity

- Mortgage requirements and lending criteria

3.4 Transaction and Service Information

- Details of properties you have viewed or expressed interest in

- Property purchase transactions and completion details

- Service agreements and fee arrangements

- Payment history and outstanding balances

- Communications with us (emails, phone calls, messages)

- Meeting notes and call recordings (where applicable)

3.5 Technical Information

- IP address and browser type (when using our website)

- Device information and operating system

- Website usage data and analytics

- Cookies and similar tracking technologies (see Cookie Policy)

3.6 Special Category Data

In limited circumstances, we may process "special category" personal data as defined under UK GDPR, such as:

- Health information (if relevant to property requirements, e.g., accessibility needs)

- Information revealing your racial or ethnic origin, religious beliefs, or political opinions (only if voluntarily provided and relevant to property preferences)

We will only process special category data where we have your explicit consent or where processing is necessary for legal compliance. You are not obliged to provide special category data, and we will only request it where genuinely necessary.

4. How We Collect Your Personal Data

We collect your personal data through various methods:

4.1 Direct Interactions

- When you enquire about our services via phone, email, or website contact forms

- When you complete application forms or service agreements

- When you provide information during property viewings or meetings

- When you communicate with us by email, phone, post, or in person

- When you subscribe to our mailing list or download resources

4.2 Third-Party Sources

- Identity verification providers and credit reference agencies (for anti-money laundering checks)

- Property vendors, estate agents, and listing portals

- Mortgage brokers, financial advisers, and other professional introducers

- Solicitors and conveyancers involved in property transactions

- Joint venture partners or business associates (where relevant)

- Publicly available sources such as Companies House, Land Registry, or property listing websites

4.3 Automated Technologies

- Cookies and tracking technologies when you visit our website (see Cookie Policy)

- Analytics tools that collect information about how you use our website

5. How We Use Your Personal Data

We only use your personal data when the law allows us to. Under UK GDPR, we must have a "lawful basis" for processing your data. The main lawful bases we rely on are:

Lawful Bases for Processing:

Contract: Processing is necessary to perform our contract with you or to take steps before entering into a contract

Legal Obligation: Processing is necessary to comply with legal or regulatory requirements

Legitimate Interests: Processing is necessary for our legitimate business interests (provided your rights don't override these interests)

Consent: You have given clear consent for us to process your data for a specific purpose

5.1 Purposes of Processing

We use your personal data for the following purposes:

Purpose: To provide property sourcing and packaging services

Type of Data: Identity, Contact, Financial, Property Investment, Transaction

Lawful Basis: Contract performance

Purpose: To identify and present suitable property opportunities

Type of Data: Property Investment, Financial, Contact

Lawful Basis: Contract performance, Legitimate interests

Purpose: To process payments and manage our financial relationship

Type of Data: Identity, Contact, Financial, Transaction

Lawful Basis: Contract performance, Legal obligation

Purpose: To conduct anti-money laundering checks and identity verification

Type of Data: Identity, Contact, Financial (source of funds)

Lawful Basis: Legal obligation (Money Laundering Regulations 2017)

Purpose: To comply with legal and regulatory obligations

Type of Data: All categories as necessary

Lawful Basis: Legal obligation

Purpose: To communicate with you about your property search and transactions

Type of Data: Identity, Contact, Transaction

Lawful Basis: Contract performance, Legitimate interests

Purpose: To introduce you to third-party professionals (solicitors, brokers, etc.)

Type of Data: Identity, Contact, Financial, Property Investment

Lawful Basis: Contract performance, Legitimate interests, Consent

Purpose: To send you marketing communications about our services

Type of Data: Identity, Contact, Property Investment

Lawful Basis: Consent, Legitimate interests (existing clients)

Purpose: To improve our services and website functionality

Type of Data: Technical, Usage data

Lawful Basis: Legitimate interests

Purpose: To handle complaints and disputes

Type of Data: Identity, Contact, Transaction, Communications

Lawful Basis: Legal obligation, Legitimate interests

Purpose: To maintain business records and accounts

Type of Data: All categories as necessary

Lawful Basis: Legal obligation, Legitimate interests

5.2 Marketing Communications

We may use your contact information to send you marketing communications about:

New property opportunities that match your investment criteria

Our services, updates, and special offers

Property market insights and investment guides

Events, webinars, or educational content

Your Rights:

You can opt out of marketing communications at any time by clicking "unsubscribe" in our emails or contacting us at [email protected]

Even if you opt out of marketing, we may still contact you about your active property transactions or service agreements.

For existing clients, we may rely on legitimate interests to send you marketing about similar services, but you can always opt out

6. Who We Share Your Personal Data With

We may share your personal data with third parties in the following circumstances:

6.1 Service Providers and Professional Advisers

We work with trusted third-party service providers who assist us in delivering our services. These may include:

Solicitors and Conveyancers: To handle legal aspects of property transactions

Mortgage Brokers and Financial Advisers: To assist with financing arrangements (with your consent)

Property Valuers and Surveyors: To conduct property assessments

Identity Verification and AML Check Providers: To comply with anti-money laundering regulations

IT and Cloud Service Providers: To host and maintain our systems and data

Payment Processors: To process financial transactions securely

Marketing and CRM Platforms: To manage client relationships and communications

Accountants and Tax Advisers: For business accounting and compliance purposes

These third parties are required to keep your information secure and confidential and may only use it for the specific purposes we have instructed them to perform.

6.2 Property Vendors and Agents

We may share relevant information with property vendors, estate agents, or developers to:

Arrange property viewings

Submit offers on your behalf

Progress property transactions

We will only share information necessary for these purposes and with your knowledge.

6.3 Joint Venture Partners and Introducers

If you were introduced to us by a third party (such as a business partner, mortgage broker, or professional network), we may share information with them about the progress of your property search or transaction, subject to appropriate confidentiality arrangements.

6.4 Legal and Regulatory Authorities

We may disclose your personal data to regulatory bodies, law enforcement, or government agencies where required by law or regulation, including:

HM Revenue & Customs (HMRC): For tax compliance

National Crime Agency (NCA): If we are required to submit a Suspicious Activity Report under money laundering regulations

Information Commissioner's Office (ICO): In response to lawful requests

Courts and Tribunals: In connection with legal proceedings

Property Ombudsman: If you make a complaint through our redress scheme

6.5 Business Transfers

If we sell, transfer, or merge any part of our business, your personal data may be transferred to the new owner or merged entity, subject to appropriate safeguards.

6.6 With Your Consent

In some cases, we may seek your specific consent before sharing your personal data with third parties, such as when introducing you to a specific professional adviser or sharing your details with a potential joint venture partner.

Data Sharing Safeguards: When we share your data with third parties, we ensure appropriate data protection measures are in place, including data processing agreements that require them to keep your information secure and use it only for specified purposes.

7. International Transfers

We primarily process your personal data within the United Kingdom. However, some of our service providers (such as cloud hosting providers or IT support services) may be located outside the UK or European Economic Area (EEA).

Where we transfer your personal data outside the UK, we ensure appropriate safeguards are in place, such as:

Transferring to countries that have been deemed to provide an adequate level of data protection by the UK Government

Using Standard Contractual Clauses approved by the ICO

Ensuring the recipient is part of a recognised data protection framework

If you would like further information about international transfers of your data, please contact us at [email protected].

8. How Long We Keep Your Personal Data

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

8.1 Retention Periods

The following retention periods typically apply:

Type of Data: Client transaction records and contracts

Retention Period: 7 years after completion or termination

Reason: Legal and tax obligations, limitation periods for potential claims

Type of Data: Anti-money laundering documentation

Retention Period: 7 years after the end of the business relationship

Reason: Money Laundering Regulations 2017

Type of Data: Financial records and invoices

Retention Period: 7 years

Reason: Tax and accounting requirements

Type of Data: Marketing consent records

Retention Period: Until consent is withdrawn, plus 3 years

Reason: Evidence of consent

Type of Data: Enquiry data (where no service provided)

Retention Period: 2 years

Reason: Business development and potential future engagement

Type of Data: Complaint records

Retention Period: 7 years after resolution

Reason: Regulatory requirements and potential claims

Type of Data: Website analytics and cookies

Retention Period: Up to 26 months

Reason: Performance analysis and improvement

8.2 Determining Retention Periods

When determining retention periods, we consider:

The nature and sensitivity of the personal data

The purposes for which we process the data

Legal and regulatory obligations (e.g., money laundering, tax, limitation periods)

Industry best practices and guidance

The risk of harm from unauthorised use or disclosure

8.3 Secure Deletion

When personal data is no longer required, we securely delete or anonymise it in accordance with our data retention and destruction procedures. This includes securely wiping electronic data and securely destroying physical documents.

9. Your Data Protection Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights regarding your personal data:

9.1 Right of Access (Subject Access Request)

You have the right to request a copy of the personal data we hold about you. This enables you to receive a copy of your data and check that we are processing it lawfully.

How to exercise: Submit a request to [email protected]. We will respond within one month of receiving your request.

9.2 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

How to exercise: Contact us at [email protected] with details of the information you believe is inaccurate.

9.3 Right to Erasure ("Right to be Forgotten")

In certain circumstances, you have the right to request that we delete your personal data, including where:

The data is no longer necessary for the purposes it was collected

You withdraw consent and there is no other legal basis for processing

You object to processing and there are no overriding legitimate grounds

The data has been unlawfully processed

Limitations: This right does not apply where we need to retain data to comply with legal obligations (e.g., money laundering records) or establish, exercise, or defend legal claims.

9.4 Right to Restriction of Processing

You have the right to request that we restrict how we use your personal data in certain circumstances, such as where:

You contest the accuracy of the data

Processing is unlawful but you don't want the data erased

We no longer need the data but you need it to establish, exercise, or defend legal claims

You have objected to processing pending verification of our legitimate grounds

9.5 Right to Data Portability

Where we process your data based on your consent or for contract performance, and the processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

9.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

Direct Marketing: You can object at any time, and we will stop processing your data for marketing purposes immediately

Legitimate Interests: You can object to processing based on legitimate interests, and we will stop unless we can demonstrate compelling legitimate grounds that override your interests

9.7 Right to Withdraw Consent

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

However, this will not affect the lawfulness of processing carried out before consent was withdrawn.

9.8 Right Not to be Subject to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing (including profiling) that produce legal effects or similarly significantly affect you. We do not currently engage in automated decision-making that would trigger this right.

9.9 How to Exercise Your Rights

To exercise any of these rights, please contact us:

Email: [email protected]

Post: HERITAGE PROPERTY PARTNERS LTD, 21 Downland Way, Durrington, Salisbury, England, SP4 8BX

We will respond to your request within one month, although this may be extended by two months for complex requests. We will inform you if we need to extend the response time.

Proof of Identity: To protect your privacy, we may ask you to verify your identity before responding to data subject requests.

No Fee Usually Required: You will not usually have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we may refuse to comply with the request in such circumstances.

10. Data Security

We are committed to keeping your personal data secure and have implemented appropriate technical and organisational measures to protect it against unauthorised or unlawful processing, accidental loss, destruction, or damage.

10.1 Security Measures

Our security measures include:

Access Controls: Restricting access to personal data on a "need to know" basis with password protection and user authentication

Encryption: Using encryption for sensitive data in transit and at rest

Secure IT Systems: Maintaining firewalls, anti-virus software, and regular security updates

Staff Training: Providing regular data protection and information security training to staff

Confidentiality Agreements: Requiring all staff and contractors to sign confidentiality agreements

Physical Security: Securing physical documents in locked cabinets with restricted access

Secure Disposal: Securely destroying or deleting data when no longer required

Third-Party Agreements: Requiring third-party service providers to implement appropriate security measures

Incident Response Plan: Maintaining procedures to detect, respond to, and recover from security incidents

10.2 Data Breaches

In the unlikely event of a data breach that is likely to result in a risk to your rights and freedoms, we will:

Notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach (where required)

Notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms

Take immediate steps to contain and remedy the breach

Document the breach and our response in accordance with UK GDPR requirements

10.3 Your Responsibility

While we implement robust security measures, please also take steps to protect your personal information:

Keep your passwords and login credentials confidential

Be cautious about sharing sensitive information via email or unsecured channels

Report any suspected unauthorised access or security concerns to us immediately

11. Cookies and Website Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyse how our website is used.

11.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help the website remember information about your visit, such as your preferences and settings.

11.2 Types of Cookies We Use

Strictly Necessary Cookies: These are essential for the website to function properly and cannot be disabled. They include cookies that enable you to navigate the website and use its features.

Analytics Cookies: These cookies collect information about how visitors use our website, such as which pages are visited most often. This helps us improve the website's functionality and user experience. We use tools like Google Analytics for this purpose.

Functionality Cookies: These cookies remember your preferences and settings (such as language or region) to provide a more personalised experience.

Marketing Cookies: With your consent, we may use cookies to track your online activity and deliver targeted advertising on third-party websites.

11.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

View and delete cookies

Block third-party cookies

Block cookies from specific websites

Block all cookies

Delete all cookies when you close your browser

Please note that blocking or deleting cookies may impact your experience on our website and prevent certain features from working properly.

For more information about cookies and how to manage them, visit www.allaboutcookies.org.

11.4 Third-Party Tracking

We may use third-party services such as Google Analytics, Facebook Pixel, or LinkedIn Insight Tag to track website usage and user behaviour. These third parties may collect information about your online activities across different websites. Please review the privacy policies of these third-party services for more information on how they use your data.

12. Links to Third-Party Websites

Our website or communications may contain links to third-party websites, such as property listing platforms, mortgage brokers, or professional service providers. This Privacy Policy applies only to our website and services.

When you follow a link to a third-party website, you should review that website's privacy policy, as we are not responsible for their privacy practices or content.

13. Children's Privacy

Our services are not directed at children under the age of 18, and we do not knowingly collect personal data from children. Property investment services are only available to adults with legal capacity to enter into contracts.

If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it as soon as possible.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Any changes will be posted on this page with an updated "Last Updated" date at the top.

If we make significant changes that materially affect how we use your personal data, we will notify you by email at [email protected] or through a prominent notice on our website before the changes take effect.

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

15. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

HERITAGE PROPERTY PARTNERS LTD

Address: 21 Downland Way, Durrington, Salisbury, England, SP4 8BX

Email: [email protected]

Company Number: 15857766

ICO Registration: ZB734355

We will respond to your enquiry as soon as possible, and in any event within one month.

16. How to Complain

We take data protection very seriously. If you are not satisfied with how we have handled your personal data or have a complaint, please contact us first at [email protected] so we can try to resolve the issue.

You also have the right to lodge a complaint with the UK's data protection supervisory authority:

Information Commissioner's Office (ICO)

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk

However, we would appreciate the opportunity to address your concerns directly before you contact the ICO, so please get in touch with us first.

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