Legal
Privacy Policy
Effective [date] · Last updated [date]
Your privacy is not an afterthought here; it is the way we work. This policy explains what personal information Kingdom Assets holds, why we hold it, and the control you keep over it. It is written to be read, not merely to satisfy the law, though it is designed to meet the UK GDPR and the Data Protection Act 2018.
1 Who we are
Kingdom Assets is a private property acquisition practice, based in Edinburgh and London, acting for UK and international buyers of significant residential, commercial, land and investment property in the United Kingdom.
For the purposes of data protection law, the data controller responsible for your personal information is [legal entity name], trading as Kingdom Assets (“we”, “us”, “our”), a company registered in Scotland under number [company number], whose registered office is at [registered office address]. We are registered with the Information Commissioner’s Office under registration number [ICO registration number].
Questions about this policy, or about how your information is handled, may be sent to our privacy contact at enquiries@kingdomassets.co.uk, marked “Privacy”, or by post to the registered office above.
2 The scope of this policy
This policy applies to personal information we collect through our website (including any private page reached by invitation), through enquiries and correspondence, through introductions, and in the course of acting for you on an acquisition. It applies to prospective clients, clients, introducers and professional contacts, and to visitors to our website.
3 The information we collect
Information you provide to us
Identity and contact details: your name, and where relevant that of your principal or representative; email address, telephone number and country of residence.
Enquiry details: the nature of the acquisition you are considering, approximate budget, property type, preferred locations, how you heard of us, and any message or instruction you send us.
Correspondence: the content of communications between us, whether by email, telephone, message or in person.
Requirements you ask us to accommodate: for example Sharia-compliant financing, or particular features in a home. Some of these may reveal your religious beliefs or other special category information; see “Special category and criminal offence information” below.
Information we require in order to act for you
Where a mandate proceeds, the law and prudent practice require us to know our client. We may therefore collect, or ask you to provide:
Proof of identity and address (for example passport, identity document or utility record);
Information on the source of funds and source of wealth for the acquisition;
Details of the intended ownership or holding structure, and of beneficial owners, trustees or a family office where relevant;
Information needed for sanctions, politically-exposed-person (PEP) and adverse-media screening;
Banking, financing or professional references where appropriate.
The law requires us to obtain this information before we act for you. If it is not provided, we will be unable to accept or continue your instruction.
Information we receive from others
From introducers and your own advisers (family offices, solicitors, private banks, trustees) who bring your matter to us with your authority;
From identity-verification and screening providers, and from sanctions and PEP databases;
From public sources and registers, such as HM Land Registry, Registers of Scotland, Companies House and reputable media;
From vendors, their agents and other market contacts in the course of pursuing a property on your behalf.
Prospective clients
We may learn of a person who may be considering a significant acquisition through a trusted introduction, or from public sources such as reputable media and published company information. If we then approach that person, we use only their professional contact details and information that is publicly available or provided by the introducer, and we tell them about this policy when we first make contact.
Information collected automatically
When you visit our website, our website platform processes technical information, such as your IP address, browser and device type, and the pages you view, to deliver the site securely and to produce aggregated visitor statistics that do not identify you. We do not use analytics, advertising or tracking cookies. See section 6.
Special category and criminal offence information
We do not ask for information about your health, religion, political opinions or other special categories of personal data except where it is needed to act for you. Where you ask us to accommodate religious or cultural requirements, we use that information only to act on your instructions, and only with your explicit consent, which you may withdraw at any time.
Politically-exposed-person screening may reveal a person’s political or public role, and sanctions and adverse-media screening may reveal information about alleged or proven offences. We process such information only where the law requires or permits it for anti-money-laundering and fraud-prevention purposes, under the conditions set out in the Data Protection Act 2018, and in line with our internal policy for this information.
4 How and why we use your information
We use your personal information only where the law allows. The table below sets out our principal purposes and the lawful basis for each.
Purpose
Lawful basis (UK GDPR)
Responding to your enquiry and holding a first conversation
Taking steps at your request before entering into a contract, and our legitimate interest in responding properly to those who contact us
Acting for you on an acquisition and providing our services
Performance of our contract with you
Client due diligence, anti-money-laundering checks, sanctions and PEP screening, and record-keeping
Compliance with a legal obligation under the Money Laundering Regulations 2017; for any special category or criminal offence information, the relevant conditions in Schedule 1 to the Data Protection Act 2018
Taking account of religious or cultural requirements you ask us to accommodate
Your explicit consent
Identifying and approaching prospective clients
Our legitimate interest in developing our practice through discreet, relevant approaches
Managing our relationship, keeping records, and establishing or defending legal claims
Our legitimate interest in running our practice properly and protecting our position
Security of our website and systems, and prevention of fraud and misuse
Our legitimate interest in keeping our systems and correspondence secure
Occasional, relevant updates to existing clients
Our legitimate interest in keeping clients informed, or your consent where the law requires it
Aggregated statistics about how our website is used
Our legitimate interest in understanding, in general terms, how the site is used, so that we can improve it
Handling a complaint about how we use your information
Compliance with a legal obligation
Where we rely on legitimate interests, we have weighed those interests against your rights, and we use your information in a way you would reasonably expect and that has a minimal privacy impact. You may ask us for more detail, or object, at any time (see section 11).
5 Marketing
We do not send newsletters or run campaigns. If we write to you with an update or a relevant opportunity, it will be rare and personal, and you may ask us to stop at any time by replying, or by writing to us at the address in section 1. We will stop promptly and without question.
6 Cookies
Our website uses only the cookies that are strictly necessary for it to work. We do not use analytics, advertising or tracking cookies; the visitor statistics described in section 3 are produced without cookies and without identifying you. Full detail is set out in our Cookie Policy.
7 When we share your information
We do not sell or rent your personal information, and we do not share it for the advertising or marketing purposes of others. Discretion is central to our work. We share your information only where it is necessary, and only with:
The professionals acting on your mandate, the solicitors, surveyors, valuers, private banks, tax and planning advisers coordinated on your behalf, and then only so far as each needs to know, and with your instruction;
Identity-verification, screening and compliance providers engaged to meet our legal obligations;
Trusted service providers who process information on our behalf under contract, for example website hosting and secure email, bound to act only on our instructions and to keep your information secure;
Regulators, HM Revenue & Customs, courts, and law-enforcement or other public authorities where we are required by law to disclose it, including under money-laundering legislation;
Our own professional advisers, such as our lawyers, accountants and insurers, where reasonably necessary;
A successor in the event of a reorganisation, merger or transfer of our business, subject to this policy.
8 Sending information outside the United Kingdom
Many of our clients live and hold interests outside the United Kingdom, including across the Gulf. Where acting for you requires us to transfer your information outside the UK, to your representatives or to a service provider, we do so only where an appropriate safeguard is in place: a country the UK Government recognises as providing adequate protection, the UK’s International Data Transfer Agreement or Addendum to the standard contractual clauses, or another lawful mechanism. You may ask us for a copy of the safeguard applied.
9 How long we keep it
We keep personal information only for as long as we need it. In practice:
Enquiries that do not proceed: kept for up to twelve months from our last contact and then deleted, unless you ask us to keep your details on file for future opportunities;
Information about prospective clients: reviewed at least every twelve months, and deleted where there is no continuing reason to hold it;
Client and transaction records: kept for the duration of our relationship and normally for six years after it ends, to meet legal, tax and professional requirements;
Anti-money-laundering records: kept for five years from the end of our business relationship or the completion of the transaction, as the law requires, unless the law requires or permits a longer period;
Requirements shared with your explicit consent: kept only while needed to act for you, or until you withdraw your consent, unless they form part of records we must keep by law.
When information is no longer required, it is securely deleted or anonymised.
10 How we protect your information
We take appropriate technical and organisational measures to keep your information secure, including encrypted transmission, secure storage, strict limits on who may access it, and routine review of our safeguards. No system can be guaranteed entirely secure, but we work continually to protect what is entrusted to us, and we will notify you and the relevant authority of a breach where the law requires.
11 Your rights
Under UK data protection law you have the right to:
Be informed about how your information is used, as set out here;
Access the personal information we hold about you;
Request correction of information that is inaccurate or incomplete;
Request erasure of your information where there is no continuing reason for us to hold it (this does not override records we must keep by law);
Request that we restrict processing in certain circumstances;
Object to processing based on our legitimate interests, and to direct marketing at any time;
Request portability of information you provided to us, where applicable;
Withdraw consent at any time where we rely on it.
To exercise any right, write to us at enquiries@kingdomassets.co.uk. We will respond within one month of receiving your request, or of receiving anything we reasonably need to confirm your identity or understand your request. Where a request is complex, we may extend this by up to two further months, and we will tell you why. There is normally no charge.
12 Complaints about your information
If you are unhappy with how we have handled your personal information, please tell us first. You can do so by email to enquiries@kingdomassets.co.uk, marked “Privacy”, through the form at the end of this page, or by post to the address in section 1. We will acknowledge your complaint within 30 days, look into it properly, and tell you the outcome without undue delay.
If you remain dissatisfied, you may complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.
13 Automated decisions
We do not make decisions about you by automated means alone, and we do not profile you in any way that produces legal or similarly significant effects.
14 Children
Our services are directed at adults. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with information, please contact us and we will remove it.
15 Other websites
Our website may link to external sites. We are not responsible for their content or privacy practices, and we encourage you to read their policies before providing them with information.
16 Changes to this policy
We may update this policy from time to time. When we do, we will change the date at the top of this page, and where a change is significant we will tell our clients directly.
17 How to contact us
For any question about this policy or your information, write to enquiries@kingdomassets.co.uk, or to [legal entity name], [registered office address]. Everything you send us is received in confidence, subject only to the legal duties described in section 7.