This Privacy Policy (the “Policy”) sets forth the terms under which Property SPV (“we,” “our,” or “us”), collects, processes, discloses, and protects personal data in connection with our website and/or services and business operations related thereto.
This Policy is issued pursuant to the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”). By accessing our website or engaging our services, you acknowledge and consent to the practices described herein.
Definitions and Interpretation
In this Policy, the following terms shall have the meanings ascribed below:
- “Personal Data” means any information relating to an identified or identifiable natural person, including, without limitation, identity, contact, financial, technical, and transactional information.
- “Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organisation, storage, adaptation, alteration, retrieval, consultation, use, disclosure, or erasure.
- “Services” refers to the provision of any and all services, past, present and future, provided by Property SPV.
- “Client” means any individual, entity, or organisation who engages Property SPV to provide Services.
- “Third-Party Providers” refers to any service provider, contractor, or affiliate engaged by Property SPV to provide Services on its behalf, including but not limited to Companies House, HMRC, AML/KYC verification providers, payment processors, CRM and cloud hosting services, legal and accounting service providers, and marketing analytics platforms.
Data Controller
Property SPV is the data controller in respect of all Personal Data collected in connection with its website and/or services and business operations related thereto. The data controller is responsible for ensuring that all Processing of Personal Data complies with applicable law, and for determining the purposes and means of such Processing.
All enquiries regarding this Policy or the Processing of Personal Data may be directed to:
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 may collect Personal Data directly from Clients in the course of providing Services. Such data may include identity information, contact details, financial information, company information, beneficial ownership information, identity verification documents, proof of address, source of funds, and correspondence.
We may collect Personal Data indirectly from publicly available sources such as Companies House, HMRC, and other statutory registers, or via Third-Party Providers engaged to perform services on our behalf.
When a Client uses our website, we may collect technical data such as IP addresses, browser types, device identifiers, and usage information. Such information may be collected through cookies, analytics, or other tracking technologies in accordance with PECR.
We may also collect Personal Data through communications, including emails, telephone calls, enquiry forms, WhatsApp messages, or other channels, for the purpose of administering our Services, responding to enquiries, and maintaining business relationships.
Purpose and Lawful Basis of Processing
We shall Process Personal Data for the purposes necessary to:
- provide and manage the Services in accordance with the contractual obligations between Property SPV and the Client;
- comply with legal obligations under UK law, including AML, KYC, Companies House, HMRC, and other statutory filings;
- detect, prevent, or investigate potential fraud, breaches of law, or contractual disputes;
- manage communications, respond to enquiries, and provide customer support;
- improve our Services, maintain security, perform analytics, and develop business operations; and
- conduct marketing communications where consent has been obtained or where permitted under PECR.
The lawful bases for Processing Personal Data are:
- necessity for the performance of a contract;
- compliance with a legal obligation;
- legitimate interests pursued by Property SPV; and
- consent, where applicable.
AML/KYC and Statutory Compliance
In the course of providing Services, Property SPV may be obliged to conduct Anti-Money Laundering (“AML”) and Know Your Client (“KYC”) checks on Clients, both directly and via Third-Party Providers.
To comply with statutory obligations, Property SPV may request and Process Personal Data including, without limitation, identity documents, proof of address, details of beneficial owners, source of funds, and other information necessary to verify the identity of Clients and associated parties.
By engaging Property SPV, Clients consent to the Processing of such Personal Data for the purpose of verifying identity, preventing fraud, and complying with statutory or regulatory requirements, including those of Companies House, HMRC, and other relevant authorities.
Clients acknowledge that failure to provide accurate or complete Personal Data may result in delays, inability to form SPV companies, or termination of Services.
Property SPV retains all AML/KYC and verification records for a period of seven (7) years following the end of the business relationship, in accordance with legal obligations.
Registered Office and Mail Handling
If and where Clients engage Property SPV to act as their registered office or service address, Property SPV may receive postal correspondence on behalf of the Client.
Property SPV shall only handle such correspondence in accordance with the instructions provided by the Client, and shall not open, inspect, or otherwise interfere with correspondence except where expressly required by law or regulation.
Personal Data contained within such correspondence shall be processed in accordance with this Policy as well as any separate contract, policy or terms formulated for that purpose, if present, and Property SPV shall implement reasonable safeguards to prevent unauthorised access or disclosure.
Clients acknowledge that the provision of registered office and mail handling services constitutes the lawful Processing of Personal Data under UK GDPR, for the purpose of facilitating statutory compliance and service delivery.
Third-Party Processors and International Transfers
Property SPV engages Third-Party Providers to facilitate the provision of Services, including, without limitation, Companies House, HMRC, payment processors, identity verification providers, CRM and cloud service providers, accounting and legal service providers, and analytics platforms.
Personal Data may be disclosed to such Third-Party Providers solely for the purpose of providing the Services and ensuring compliance with legal obligations.
7.3 Property SPV shall ensure that all Third-Party Providers are bound by contractual obligations requiring compliance with UK GDPR and the Data Protection Act 2018, including the implementation of appropriate technical and organisational security measures.
Where Personal Data is transferred outside the United Kingdom, Property SPV shall ensure that appropriate safeguards are in place, including, without limitation, the use of Standard Contractual Clauses, UK adequacy provisions, or secure encrypted storage and transmission methods.
Data Retention
Property SPV shall retain Personal Data only for as long as necessary to provide Services, comply with legal obligations, resolve disputes, enforce agreements, or fulfil other legitimate business purposes.
Not withstanding anything mentioned in any other section of this Policy, retention periods are generally as follows, subject to regulatory requirements:
- Enquiry and Contact Records: 24 months
- Company Formation, Registration, and Compliance Records: Six (6) years following termination of Services
- AML/KYC and Identity Verification Records: Five (5) years following termination of Services
- Tax and Financial Records: Six (6) years following termination of Services
- Records Relevant to Legal Claims or Disputes: As required by law.
Upon expiry of the retention period, Personal Data shall be securely deleted or anonymised.
Cookies and Online Tracking
Property SPV’s website uses cookies and similar technologies to enable website functionality, analyse usage patterns, improve user experience, and deliver targeted communications where consented.
Cookies may include essential cookies necessary for the operation of the website, analytics cookies to measure performance, and marketing cookies for promotional purposes.
Non-essential cookies will only be placed on the device of a Client or website visitor upon obtaining explicit consent.
Client Rights under UK GDPR
Clients and website users have the following rights under UK GDPR:
- The right to access Personal Data held about them;
- The right to request correction of inaccurate or incomplete Personal Data;
- The right to request erasure of Personal Data where lawful;
- The right to restrict Processing of Personal Data;
- The right to object to Processing of Personal Data;
- The right to receive Personal Data in a structured, commonly used, machine-readable format and request transfer to another data controller;
- The right to withdraw consent at any time where Processing is based on consent;
- The right to lodge a complaint with the Information Commissioner’s Office (“ICO”).
Requests to exercise any of the above rights may be submitted to info@propertyspv.co.uk, and will be handled in accordance with statutory timelines.
Security
Property SPV implements appropriate technical and organisational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, including:
- Secure encrypted storage of identity and financial records;
- Role-based access controls and password protection;
- Secure payment processing mechanisms;
- Periodic audits and security assessments of systems and processes.
While Property SPV endeavours to safeguard Personal Data, no method of electronic transmission or storage can be guaranteed to be 100% secure.
Marketing Communications
Property SPV may send marketing communications regarding Services, offers, and educational materials where consent has been provided or where a soft opt-in under PECR applies.
Recipients of marketing communications may opt out at any time by using the unsubscribe facility provided or by contacting info@propertyspv.co.uk.
Changes to this Privacy Policy
Property SPV may amend this Policy from time to time to reflect changes in services, law, or regulatory guidance.
Any material changes will be posted on the website with a revised “Last Updated” date and, where appropriate, communicated to Clients.
Governing Law and Jurisdiction
This Policy, the collection and Processing of Personal Data, and any disputes arising from or in connection with it shall be governed by and construed in accordance with the laws of England and Wales.
The courts of England and Wales shall have exclusive jurisdiction to settle any disputes relating to this Policy or the Processing of Personal Data by Property SPV.
Contact Information
For questions, requests, or complaints regarding this Privacy Policy, Clients and website visitors may contact Property SPV as follows:
Email: info@propertyspv.co.uk
Telephone: +44 20 4591 1945
Registered Office: 809 Salisbury House, 29 Finsbury Circus, London, EC2M 7AQ