Draft for review – this policy has not yet been reviewed by a qualified solicitor.
This policy explains how Portfolio Sales Consultancy Ltd ("PSC", "we", "us", "our") collects, uses and protects personal data when you use our website at portfoliosalesconsultancy.co.uk, send us an enquiry, or deal with us in connection with the sale of a property portfolio. It is written to meet the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
The data controller responsible for your personal data is Portfolio Sales Consultancy Ltd, a company registered in England and Wales with company number 16090157. Our registered office is Market Chambers, 2b Market Place, Shifnal, Shropshire TF11 9AZ.
- Email: contact@portfoliosalesconsultancy.co.uk
- Telephone: 01952 433 399
- Post: Portfolio Sales Consultancy Ltd, Market Chambers, 2b Market Place, Shifnal, Shropshire TF11 9AZ
- ICO registration number: ZB848912 (view on the ICO register)
2. The Personal Data We Collect
2.1 Information you give us through our enquiry forms
- Your name
- Email address
- Telephone number
- Postcode area of your properties
- Number of properties in your portfolio
- Optional portfolio details you choose to give us (for example, approximate value, tenancy position or your reasons for selling)
- Anything you write in the message field
Please do not include more information about tenants or other people than is needed for your enquiry.
2.2 Information you give us if you go on to work with us
If you decide to proceed after an initial conversation, we will collect further information needed to act for you and to meet our legal obligations. This may include identity documents, proof of address, details of company ownership where properties are held in a company, property and tenancy information, and correspondence with you, your solicitor and your lender.
2.3 Information collected when you use the website
- Enquiry submission data: when you submit a form, our script records the date and time, your IP address and the page you submitted from, and includes them in the enquiry email sent to us.
- Cookie choice: an item called
psc_cookies_acceptedis stored in your browser to remember your cookie preference. - Third-party content: our pages load fonts from Google Fonts and images from Unsplash (images.unsplash.com). To deliver these, your browser connects directly to those providers' servers, which receive your IP address and basic browser information.
Analytics (Google Analytics and Microsoft Clarity) run only if you choose "Accept All" on our cookie banner. If you choose "Essential Only", they do not run. We do not use advertising cookies. See our Cookie Policy for details.
3. How We Use Your Data and Our Lawful Bases
We only use your personal data where we have a lawful basis under the UK GDPR:
- Responding to your enquiry and discussing a possible sale – including preparing a portfolio appraisal and explaining how we could help. Lawful basis: taking steps at your request before entering into a contract (Article 6(1)(b)).
- Providing our services if you instruct us – including introducing your portfolio to prospective buyers and coordinating with solicitors and lenders through to completion. Lawful basis: performance of a contract (Article 6(1)(b)).
- Running and protecting our business and website – including keeping records of enquiries, preventing spam and misuse of our forms, and handling complaints or legal claims. Lawful basis: our legitimate interests in operating our business securely and effectively (Article 6(1)(f)).
- Anti-money laundering and identity checks – carrying out customer due diligence (know-your-customer checks) and keeping the related records. Lawful basis: compliance with a legal obligation under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (Article 6(1)(c)).
- Optional marketing – sending you occasional updates, only if you have opted in. Lawful basis: consent (Article 6(1)(a)), which you can withdraw at any time.
Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and freedoms. You can ask us for more information about this.
4. Who We Share Your Data With
We do not sell your personal data. We share it only where necessary, with the following categories of recipient:
- Our website hosting and email provider (Hostinger), which hosts the website, processes enquiry form submissions and carries our email on our behalf.
- Professional advisers, such as our solicitors, accountants and insurers, where needed to run our business or deal with a legal matter.
- Prospective buyers, only with your agreement and after they have signed a non-disclosure agreement. Details are limited to what a buyer needs to assess the portfolio.
- Your own solicitor, lender or other representatives, where you ask us to deal with them during a sale.
- Regulators, law enforcement and other public authorities, where we are required by law to do so, including reporting obligations under anti-money laundering law.
5. Transfers Outside the UK
Google (which provides Google Fonts and, if you choose "Accept All", Google Analytics), Microsoft (which provides Microsoft Clarity, if you choose "Accept All") and Unsplash may process your IP address outside the UK, including in the United States, when your browser loads content or analytics from their servers. [Details of the transfer safeguards relied on, and of where our hosting and email provider stores data, to be confirmed by PSC.]
6. How Long We Keep Your Data
- Enquiries that do not proceed: [retention periods to be confirmed by PSC]
- Client and transaction records: [retention periods to be confirmed by PSC]
- Anti-money laundering records: the Money Laundering Regulations 2017 generally require customer due diligence records to be kept for five years after the business relationship ends. We will then delete them unless we are required or permitted by law to keep them longer.
- Marketing preferences: until you withdraw your consent, after which we keep a record that you have opted out so we do not contact you again.
7. Your Rights
Under data protection law you have the right to:
- Access – ask for a copy of the personal data we hold about you
- Rectification – ask us to correct inaccurate or incomplete data
- Erasure – ask us to delete your data in certain circumstances
- Restriction – ask us to limit how we use your data in certain circumstances
- Data portability – ask for data you gave us in a machine-readable format, where processing is based on contract or consent
- Object – object to processing based on our legitimate interests, and to direct marketing at any time
- Withdraw consent – at any time, where we rely on consent; this does not affect processing already carried out
Some rights are limited – for example, we may be legally required to keep anti-money laundering records even if you ask us to delete them. To exercise any of these rights, contact us using the details in section 1. We will respond within one month, which may be extended in limited circumstances allowed by law.
8. Security
We use appropriate technical and organisational measures to protect your personal data, including HTTPS encryption on our website and anti-spam measures on our forms. Access to client information is limited to those who need it.
9. Marketing
We will only send you marketing if you have opted in. You can opt out at any time by emailing us or using the unsubscribe option in any marketing message.
10. Complaints
If you have concerns about how we use your personal data, please contact us first so we can try to resolve them. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:
- Website: ico.org.uk
- Helpline: 0303 123 1113
11. Changes to This Policy
We may update this policy from time to time, for example if we change how we use personal data or introduce new website tools. The "Last updated" date at the top of this page shows when it was last revised.