Privacy Policy

1. Who We Are

DifferentEstate ("we", "our", or "us") operates as a bespoke residential estate agency and property consultancy in the United Kingdom. We are dedicated to upholding the highest standards of data integrity, confidentiality, and regulatory adherence in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Personal Data We Collect

To deliver our valuation, property management, buying, and selling services, we collect distinct categories of personal data depending on your relationship with us:

• Identity and Contact Data: Full legal names, title, residential addresses, telephone numbers, and email addresses.
• Property and Transaction Data: Ownership documentation, title deeds, council tax band, mortgage provider details, survey outcomes, and property specifications.
• Compliance and Due Diligence Data: Passport copies, driving licences, utility bills, source of funds documentation, and PEP / Sanction screening records (pursuant to Money Laundering Regulations).
• Financial Data: Bank account details for sales proceeds, deposit transaction confirmations, and mortgage Agreement in Principle (AIP) documents.
• Digital and Technical Data: IP addresses, browser types, interaction logs, and referral channels collected during portal and website visits.

3. How We Use Your Data & Lawful Bases

We process your personal information strictly when permitted under Article 6 of the UK GDPR. The lawful grounds applicable to our estate agency operations include:

4. Who We Share Data With

We never sell, rent, or trade your personal data. Where strictly necessary to execute our obligations and facilitate property transactions, data is shared with vetted third parties:

• Conveyancing Solicitors and Legal Representatives: To progress sales contracts and exchange protocols.
• Surveyors, EPC Assessors, and Professional Photographers: For valuation assessments and marketing material compilation.
• AML Verification Partners: Secure electronic identity verification platforms operating in full compliance with UK data security frameworks.
• Property Portals: Rightmove, Zoopla, and PrimeLocation for active listing distribution (anonymised listing details).
• Statutory Authorities: HMRC, the National Crime Agency (NCA), and law enforcement bodies where legally mandated.

5. Data Retention Periods

We retain personal data only for as long as is necessary to satisfy the purposes for which it was gathered, including legal, accounting, and anti-money laundering requirements:

• Active Clients and Completed Transactions: 7 years from transaction completion or contract termination, ensuring compliance with HMRC and AML statutory audit obligations.
• Uncontacted Enquiries and Viewing Prospects: 12 months from the date of last contact or property withdrawal, following which data is permanently deleted or anonymised.
• AML Identification Files: 5 to 7 years in strict compliance with Regulation 40 of The Money Laundering Regulations 2017.

6. Your UK GDPR Rights

Under UK data protection legislation, you possess distinct legal rights regarding the personal information we maintain:

• Right of Access (Subject Access Request): Request a copy of the personal records we hold concerning you.
• Right to Rectification: Request correction of inaccurate, incomplete, or out-of-date information.
• Right to Erasure ('Right to be Forgotten'): Request deletion of your data where no overriding statutory or contractual retention obligation applies.
• Right to Restrict Processing: Request suspension of data processing under defined legal scenarios.
• Right to Data Portability: Request the transfer of your structured data to another provider where technically feasible.
• Right to Object: Object to processing founded upon legitimate interests or direct marketing operations.

7. Automated Processing & Profiling

We do not conduct automated decision-making or algorithmic profiling that produces legal or comparably significant effects on our clients. Automated tools may be used solely to filter property matching criteria against registered buyer preferences.

8. Marketing Communications

You will receive marketing updates, off-market property alerts, and market insight newsletters only if you have provided explicit opt-in consent or where an active commercial relationship exists. You may withdraw consent at any moment via the unsubscribe link embedded in all communications or by contacting our Data Protection Officer.

9. Data Security Measures

We have implemented robust technical and organisational security protocols to prevent personal information from being accidentally lost, altered, disclosed, or accessed without authorisation. These measures encompass 256-bit SSL encryption, restricted role-based internal permissions, routine penetration assessments, and encrypted offsite backups.

10. Cookies & Tracking Technologies

Our website utilises essential, functional, and analytical cookies to ensure optimal navigation and evaluate user traffic patterns. Non-essential cookies require your explicit consent through our cookie management interface prior to activation.

11. Changes to This Policy

We review this policy on an ongoing basis to ensure continued alignment with regulatory guidance. Any material amendments will be posted on this page with an updated revision date. We encourage regular review of this policy.

12. How to Complain

If you have any concerns regarding our handling of your data, please contact our team directly so we may address your enquiry promptly. You also retain the statutory right to lodge a formal complaint with the UK supervisory authority:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 | Website: ico.org.uk

13. Contact Us

To exercise your data protection rights, submit a subject access request, or obtain clarification regarding this policy, please reach out to our designated Data Protection Lead:

Email: [email protected]
Postal Address: DifferentEstate Compliance, 14 Berkeley Street, Mayfair, London, W1J 8DX, United Kingdom