Privacy Policy

Definitions and Interpretation

In this Policy, the following terms have the meanings given below:

• “Personal Data” means any information relating to an identified or identifiable natural person, including identity, contact, financial, technical and transactional information.
• “Processing” means any operation performed on Personal Data, whether or not by automated means, including collection, recording, organisation, storage, adaptation, alteration, retrieval, consultation, use, disclosure or erasure.
• “Services” means any and all services, past, present and future, provided by Property SPV.
• “Client” means any individual, entity or organisation that engages Property SPV to provide Services.
• “Third-Party Providers” means service providers and contractors we engage to help us provide the Services, including identity verification and anti-money laundering (“AML”) screening providers, payment processors, CRM, IT and cloud hosting providers, legal and accounting service providers, and marketing analytics platforms.
• “Government Bodies” means Companies House, HM Revenue & Customs (“HMRC”), law enforcement agencies and other regulators and public authorities to which we report or disclose information.

Data Controller

Property SPV (Company Registration: 10510918), registered with the Information Commissioner’s Office (“ICO”) under number ZA567364, is the data controller for the Personal Data described in this Policy. As controller, we decide how and why your Personal Data is used, and we are responsible for making sure that use complies with the law.

For any questions about this Policy or how we use your Personal Data, please contact our Data Protection Officer Jony Mainaly at jony@ukpa.co.uk, or contact our team directly at:

Email: info@propertyspv.co.uk
Telephone: +44 20 4591 1945
Registered Office: 809 Salisbury House, 29 Finsbury Circus, London, EC2M 7AQ

Collection of Personal Data

We collect Personal Data directly from Clients when we provide the Services. This may include identity information, contact details, financial information, company information, beneficial ownership information, identity verification documents, proof of address, source of funds and correspondence. Clients may also give us Personal Data about other people connected with their company, such as directors, shareholders and beneficial owners.

We may also get your data from Companies House, identity verification and AML screening providers, and public registers. We may also receive information from HMRC and other Government Bodies in the course of providing the Services.

When you use our website, we may collect technical data such as IP addresses, browser types, device identifiers and usage information. This is collected through cookies and similar technologies in accordance with PECR (see “Cookies and Online Tracking” below).

We may also collect Personal Data through emails, telephone calls, enquiry forms, WhatsApp messages and other channels. We use this to administer our Services, respond to enquiries and maintain our business relationships.

How We Use Your Data and Our Legal Basis

The table below shows what we use Personal Data for, what data is involved, and the legal basis we rely on under Article 6 of the UK GDPR.

Where we rely on legitimate interests, we have checked that our interests are not outweighed by your rights. Where we rely on consent, you can withdraw it at any time.

Anti-Money Laundering and Identity Checks

We carry out these checks because we are legally required to under the Money Laundering Regulations 2017. As a company formation and registered office provider, we must verify the identity of our Clients and of individuals connected with them, such as directors, shareholders and beneficial owners. We do this directly and through Third-Party Providers.

For these checks, we may ask for and Process identity documents, proof of address, details of beneficial owners, source of funds and other information needed to verify identity.

Our checks may involve information about criminal convictions or public positions held. This can arise from sanctions and politically exposed person (PEP) screening. We process this only where the law allows, to meet our anti-money laundering obligations.

Personal data we collect for anti-money laundering checks will only be used to prevent money laundering, terrorist financing and proliferation financing. We will not use it for anything else, including marketing, unless the law allows it or you have given your consent.

If you do not give us accurate or complete information, there may be delays, we may be unable to form your company, or we may have to end the Services.

We keep identity and anti-money laundering records for 5 (five) years after our relationship ends, unless the law or legal proceedings require us to keep them longer.

Registered Office and Mail Handling

Where Clients engage Property SPV to act as their registered office or service address, we may receive post on their behalf.

We handle such post only in line with the Client’s instructions. We do not open, inspect or otherwise interfere with it except where the law or a regulator expressly requires us to.

Personal Data contained in such post is processed in line with this Policy and any separate contract, policy or terms for that service. We apply reasonable safeguards to prevent unauthorised access or disclosure.

Who We Share Your Data With

We share Personal Data only where we need to provide the Services or meet our legal obligations. We share it with three groups:

• Suppliers who work for us. These are Third-Party Providers such as identity verification and AML screening providers, payment processors, IT, CRM and cloud hosting providers, and legal and accounting service providers. They act on our instructions and are bound by contracts requiring them to comply with the UK GDPR and the Data Protection Act 2018, including appropriate technical and organisational security measures.
• Government Bodies. These include Companies House, HMRC and law enforcement agencies. We disclose information to them where the law requires it, for example during statutory filings and reports. They use the data under their own legal powers, not on our behalf.
• Our sister company, UK Property Accountants. Where you have asked us to, or where you would reasonably expect it, we may share your contact details and information about your company with our sister company, UK Property Accountants, so they can offer accounting and tax services.

International Transfers

Some of our suppliers and team members are based outside the UK, including in Nepal and India. When we transfer data, we use the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Where the UK has made an adequacy decision for a country, we may rely on that instead. You can ask us for a copy of the safeguards we use.

Data Retention

We keep Personal Data only for as long as we need it to provide the Services, meet legal obligations, resolve disputes, enforce agreements or fulfil other legitimate business purposes. Our standard retention periods are:

When a retention period ends, we securely delete or anonymise the Personal Data.

Cookies and Online Tracking

Our website uses cookies and similar technologies to make the website work, analyse how it is used, improve your experience and, where you have agreed, deliver targeted communications.

These may include essential cookies needed for the website to operate, analytics cookies to measure performance, and marketing cookies for promotional purposes.

We place non-essential cookies on your device only after you have given your consent. You can change your choices at any time through your browser’s cookie settings. See our Cookies Policy for more detail.

Your Rights

Under the UK GDPR, you have the following rights:

• the right to access the Personal Data we hold about you;
• the right to ask us to correct inaccurate or incomplete Personal Data;
• the right to ask us to erase your Personal Data, where the law allows;
• the right to ask us to restrict Processing of your Personal Data;
• the right to object to Processing of your Personal Data, and an absolute right to object to direct marketing;
• the right to receive your Personal Data in a structured, commonly used, machine-readable format and to ask us to transfer it to another controller;
• the right to withdraw consent at any time, where we rely on consent;
• rights relating to automated decision-making, explained below; and
• the right to complain to the ICO.

Automated decisions: Some of our identity checks use automated tools. We do not make decisions about you based solely on automated processing. If any significant decision about you is made solely by automated means, for example the result of an automated ID check, we will tell you. You can make representations about the decision, ask for a person to review it, and contest it.

How to make a request: Send your request to info@propertyspv.co.uk. We will reply within one month. If your request is complex, or you have made several requests, we may extend this by up to two further months; if so, we will tell you why within the first month.

The ICO: You can contact the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

Complaints

If you are unhappy with how we have used your data, contact info@propertyspv.co.uk or use our contact form. We will acknowledge your complaint within no more than 30 days of receiving it. We will look into it, keep you updated, and tell you the outcome without undue delay.

You can also complain to the ICO at any time (see “Your Rights” above).

Security

We use appropriate technical and organisational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include:

• secure encrypted storage of identity and financial records;
• role-based access controls and password protection;
• secure payment processing; and
• periodic audits and security assessments of our systems and processes.

While we work hard to protect Personal Data, no method of electronic transmission or storage can be guaranteed to be 100% secure.

Marketing Communications

We may send you news, guides and offers about our Services where you have given consent, or where the “soft opt-in” under PECR applies because you are an existing Client.

You can opt out at any time by using the unsubscribe link in any email or by contacting info@propertyspv.co.uk. We never use data collected for anti-money laundering checks for marketing.

Changes to this Policy

We may update this Policy from time to time to reflect changes in our Services, the law or regulatory guidance. We will post any material changes on our website with a revised “Last updated” date and, where appropriate, tell Clients directly.

Governing Law

This Policy is governed by the laws of England and Wales. However, this does not affect your right to complain to the ICO or your rights as a consumer.

Contact Information

For questions, requests or complaints about this Policy, please contact us:

Email: info@propertyspv.co.uk
Telephone: +44 20 4591 1945
Registered Office: 809 Salisbury House, 29 Finsbury Circus, London, EC2M 7AQ