Privacy Policy

The General Data Protection Regulation (“GDPR”) governs the controlling and processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and gives those individuals certain rights and remedies regarding that information.

This notice provides you with the required information when you provide us with your data. It lays out the essentials, such as what, where, when, and how, regarding the personal information collected. This should help you feel more confident about the privacy and security of your personal information.

Please read this Privacy Notice carefully. By visiting our website or using our services, you indicate your agreement to our use of your personal information as set out in this Privacy Notice.

Identity and contact details of the Data Controller

Wandle Real Estate Partners (company number 15583335) whose registered office is at;

WREP UK Ltd t/a Wandle Real Estate Partners
Zeeta House
200 Upper Richmond Road
London
SW15 2SH

is the Data Controller and is committed to protecting the rights of individuals in line with the GDPR.

Contact details of the Data Protection Officer

Wandle Real Estate Partners has appointed a Data Protection Officer who can be contacted through contact@wandlepartners.com. This individual has oversight responsibility for the usage and processing of personal data. Any questions relating to data security should be directed to the Data Protection Officer.

Information we collect about you.

When do we collect information?

We collect information when you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, email, or post. We also collect information when you provide feedback or complete a contact form on our website.

As explained below, we may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks.

What information will we collect and why?

We may collect the following information depending on the service provided:

• Your contact details, such as your name, address, telephone number and email address;
• Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
• Passport details, driving licence and utility bills;
• Details of the services you request from us;
• Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
• Details of your employment status, income and source of wealth.

Sometimes, you are not obliged to provide us with any personal data. Still, if you have requested information or a service from us, we cannot provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you so that we can verify your identity. This is to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and any other applicable legislation and to prevent crime and fraud.
You are obliged to provide this information, and if you do not, we will be unable to provide you with our services.

We also collect information when you voluntarily complete customer surveys, provide feedback, or complete a contact form on our website.

We use information held by you in the following ways:

• to process your application to use our services;
• to undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for crime prevention and fraud prevention;
• to comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to help protect your information and prevent unauthorised access to it;
• to deal with any queries, complaints or problems reported by you;
• to generate statistics relating to the use of our website, such as the popularity of certain features or services. We do not use personally identifiable information for these purposes;
• if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
• to notify you of changes to our services; and
• to help improve the services we provide to you.

Unless otherwise stated in this Privacy Notice, the legal basis for our use of your data will be that this information is required for one or more of the legitimate interests described above.

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.

We may disclose your information to:

• Businesses that are legally part of the same group of companies within Wandle Real Estate Partners or that become part of that group;
• Our IT providers, services providers and agents to provide and maintain the provision of the services;
• Our appointed auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants), to the extent that they require access to the information to advise us;
• Fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
• We may also be required to share information with auditors appointed by the providers of such products or services;
• The regulators, the Financial Conduct Authority, or any relevant regulatory authority where they are entitled to require disclosure;
• Meet applicable law, the order of a Court or market rules and codes of practice relevant to the circumstances at the time;
• Investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
• Relevant tax, payments and customs authorities, who may pass this on to tax authorities in other jurisdictions. The tax regulations require us to collect information about each investor’s tax residency;
• prospective seller or buyer of such business or assets if we sell or buy any business or assets, in which case we will disclose your personal information. If a third party acquires all of Wandle Real Estate Partners’ assets, personal information held by it about its clients may be one of the transferred assets.

We will not lend or sell your information to third parties.

We are committed to keeping your personal data only for as long as necessary to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.

We retain copies of our customer contracts to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime, and anti-money laundering checks (as required by law) for five years after termination or expiry of our contract with you. We retain details of complaints for five years from the date of receipt.

We shall keep records of the following for five years:

• electronic communications and minutes of face-to-face meetings;
• suitability and appropriateness assessments;
• periodic statements (for example, valuations); and
• all transactions in financial instruments on your behalf (including information about your identity).

Wandle Real Estate Partners retains copies of all the records above for a maximum of seven years.

We may share your personal information with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA), whose data protection laws may not be as extensive as those that apply to us. Where we do so, we will ensure that we do this per the Acts and take appropriate measures to ensure that the level of protection that applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect to which there is a European Commission adequacy decision or, where this is not the case, by using model clauses that the European Commission has approved.

You have a key right to learn and have access to what personal information is held by Wandle Real Estate Partners and can ask us for details on this.

When we receive such a request, we will endeavour to provide you with these details without delay and, at the latest, within one month of receipt. Where requests are complex or numerous, we may extend the compliance period by two more months. In such instances, Wandle Real Estate Partners will inform you within one month of receiving the request and explain why the extension is necessary.

When Wandle Real Estate Partners receives a subject access request, we will provide a copy of the information free of charge. However, we may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean we will charge for all subsequent access requests; instead, Wandle Real Estate Partners reserves the right to charge a fee based on the information’s administrative cost.

If, after reviewing a request, the Data Protection Officer believes it is manifestly unfounded or excessive, mainly if it is repetitive, Wandle Real Estate Partners may charge a ‘reasonable fee,’ which will be decided on a case-by-case basis. Wandle Real Estate Partners may refuse to respond to such requests in certain circumstances.

You also have the following rights (unless exemptions apply), which you can exercise by contacting us using the details below.

The right:

• To ask us not to process your data for marketing purposes;
• To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
• To request the rectification or completion of personal data which is inaccurate or incomplete;
• To restrict or object to the processing of your data (from 25th May 2018 onwards);
• To request its erasure under certain circumstances;
• In certain circumstances, to receive your data, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller without hindrance or to have that personal data transmitted to another data controller, where technically feasible (from 25th May 2018 onwards);
• To be informed about any use of your data to make automated decisions about you and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
• You can complain to your data protection authority, the Information Commissioner’s Office (United Kingdom), about the way in which your data is being used.

When you contact us to exercise any of the rights above, we may ask you to provide some additional information to verify your identity, such as your name, address and proof of identity. If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at:

E-mail: contact@wandlepartners.com

Alternatively, if you would like to contact the Data Protection Authority, please use the contact details below.

United Kingdom: Commissioner’s Office

Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.