PRIVACY POLICY

1. Introduction
Zivac Properties respects your privacy and is committed to protecting your personal
information.
This Privacy Policy explains how we collect, use, store, share and protect personal
information when you:
visit our Website;
create an account;
search for property;
submit a property enquiry;
request a viewing;
make an offer or express interest in a property;
use our “Find Me a Property” service;
enquire about a commercial property;
enquire about a property investment opportunity;
submit information as a prospective investor;
register as an agent or agency;
upload or manage property listings;
list or enquire about a property;
request a third-party property service;
become or apply to become a partner;
communicate with us by telephone, email, WhatsApp, live chat, social media or another
method;
subscribe to marketing communications; or
otherwise interact with our business.
This Privacy Policy applies to personal information processed by:
Legal company name: [FULL LEGAL COMPANY NAME]
Trading name: Zivac Properties
Company number: [COMPANY NUMBER]
Registered office: [REGISTERED OFFICE ADDRESS]
Business address: [BUSINESS ADDRESS, IF DIFFERENT]
Email: [PRIVACY EMAIL ADDRESS]
Telephone: [TELEPHONE NUMBER]
ICO registration number: [ICO REGISTRATION NUMBER, ONCE CONFIRMED]
For the purposes of applicable data-protection law, [LEGAL COMPANY NAME] is the
controller of personal information where it determines why and how that information is
processed.
In some circumstances, another organisation, such as an independent estate agency, service
provider or professional adviser, may be a separate controller of information shared with it.
2. Data-Protection Laws
We process personal information in accordance with applicable UK data-protection and
privacy laws, including, as applicable:
the UK General Data Protection Regulation;
the Data Protection Act 2018;
the Privacy and Electronic Communications Regulations 2003;
the Data (Use and Access) Act 2025; and
other applicable privacy and electronic-communications requirements.
3. Personal Information We May Collect
The information we collect depends on how you interact with us.
3.1 Identity information
This may include:
full name;
title;
date of birth where necessary;
signature;
username or account identifier;
copies or details of identification documents where required for verification;
photograph where provided or necessary;
nationality where relevant and lawful.
3.2 Contact information
This may include:
residential address;
business address;
correspondence address;
email address;
telephone number;
WhatsApp number;
communication preferences.
3.3 Property-search information
This may include:
preferred location;
property type;
intended use;
budget;
price range;
rental range;
property size requirements;
number of bedrooms;
commercial space requirements;
preferred tenure;
preferred moving or completion date;
financing position;
mortgage status;
cash-buyer status;
notes about your requirements.
3.4 Property-owner and seller information
This may include:
property address;
ownership information;
contact information;
property details;
title or tenure information;
photographs;
floor plans;
valuation information;
marketing instructions;
availability;
requested price;
relevant correspondence.
3.5 Agent and agency information
This may include:
agent name;
agency name;
job title;
business email address;
business telephone number;
agency address;
profile photograph;
professional biography;
social-media details;
Website address;
agency logo;
property listings;
lead and enquiry information;
account activity;
commission or commercial arrangement information;
regulatory or professional information where relevant.
3.6 Investment-enquiry information
Where you enquire about potential property opportunities, we may collect:
amount of capital potentially available;
preferred investment amount;
investment objectives;
desired income objectives;
investment timeframe;
attitude to relevant commercial considerations;
property preferences;
experience with property;
whether funds are available;
expected source of funds;
whether financing may be required;
preferred contact method;
consultation notes;
information necessary to assess whether we can lawfully discuss or offer a particular
opportunity.
Submitting an investment enquiry does not itself create an investment relationship.
3.7 Financial and transaction information
Where necessary, this may include:
proof of funds;
bank information;
payment information;
transaction history;
offer amount;
proposed purchase amount;
deposit information;
invoicing information;
commission information;
payment status;
financing information;
source-of-funds information.
We do not intend to collect more financial information than reasonably necessary for the
relevant purpose.
3.8 Compliance and verification information
Where appropriate or required, this may include:
identity verification results;
address verification;
company information;
Companies House information;
beneficial ownership information;
source-of-funds information;
source-of-wealth information;
sanctions screening results;
politically exposed person screening;
fraud-prevention indicators;
due-diligence records;
compliance notes.
3.9 Partner-service enquiry information
If you request a property-related service, we may collect information about:
the service required;
property address;
project type;
budget;
preferred timeframe;
description of the work;
contact details;
documents or photographs you choose to provide;
the partner to whom the enquiry is referred;
referral status;
whether a service proceeds.
3.10 Communication information
We may retain information contained in:
emails;
telephone notes;
call recordings where used lawfully;
WhatsApp messages;
live-chat messages;
contact forms;
complaints;
social-media communications;
meeting notes;
other correspondence.
3.11 Technical and usage information
When you use the Website, we may collect:
IP address;
device type;
browser type;
operating system;
approximate location derived from technical information;
Website pages viewed;
referral source;
date and time of visits;
session information;
cookie identifiers;
Website interaction data;
security logs;
account login activity.
The exact information collected will depend on the technology and services used on the
Website.
3.12 Marketing information
This may include:
marketing preferences;
consent records;
unsubscribe records;
preferred property categories;
engagement with marketing communications;
campaign information.
3.13 Information about criminal allegations or offences
We do not routinely seek criminal-offence information.
Where such information is processed, it will only be handled where there is a valid lawful
basis and any additional legal condition required by applicable law.
3.14 Special category information
We do not normally need to collect special category personal information.
Where it becomes necessary for a specific lawful purpose, we will only process it where an
appropriate lawful basis and additional legal condition apply.
Please avoid sending highly sensitive personal information unless it is genuinely necessary
and an appropriate method of communication has been agreed.
4. How We Collect Personal Information
We may collect personal information:
4.1 Directly from you
For example, when you:
create an account;
complete a form;
contact us;
make an enquiry;
request a viewing;
submit an offer;
upload a listing;
request a service;
request an investment consultation;
provide verification documents;
enter into an agreement;
respond to a survey;
communicate with our team.
4.2 From agents, agencies and property partners
We may receive information where:
an agent refers you;
a partner sends us an enquiry;
an agency uploads a property containing relevant contact information;
a joint transaction requires information to be shared.
4.3 From service providers and professional advisers
We may receive information from:
mortgage advisers;
solicitors;
surveyors;
compliance providers;
identity verification providers;
payment providers;
contractors;
other authorised professionals.
4.4 From public sources
Where lawful and relevant, we may obtain information from sources such as:
Companies House;
HM Land Registry or other property records;
company websites;
professional directories;
publicly accessible business information;
sanctions or compliance databases;
other legitimate public sources.
4.5 Automatically through technology
We may collect information through:
cookies;
analytics tools;
Website logs;
security technology;
CRM systems;
embedded forms;
chat systems;
advertising technology, subject to applicable consent requirements.
5. Why We Use Personal Information and Our
Lawful Bases
We only process personal information where we have an appropriate lawful basis.
Depending on the circumstances, our lawful bases may include:
5.1 To take steps at your request or perform a contract
We may use personal information to:
create and manage an account;
respond to a service request;
arrange a viewing;
manage a property instruction;
provide an agreed service;
administer a partnership;
manage a listing;
enter into or perform a contract;
process agreed payments.
5.2 Legitimate interests
We may process information where necessary for our legitimate business interests or those
of another person, provided those interests are not overridden by your rights and interests.
These purposes may include:
operating and improving our business;
responding to enquiries;
matching property seekers with relevant opportunities;
generating and managing leads;
communicating with agents and partners;
maintaining business relationships;
preventing fraud;
maintaining Website security;
establishing, exercising or defending legal claims;
keeping business records;
measuring service performance;
improving customer service;
protecting our business.
Where required, we will consider whether the processing is necessary and proportionate
and balance relevant interests against the rights of individuals.
5.3 Legal obligation
We may process personal information where necessary to comply with legal obligations,
including obligations relating to:
anti-money laundering;
fraud prevention;
taxation;
accounting;
court orders;
law-enforcement requests;
regulatory requirements;
record keeping;
data-protection law.
5.4 Consent
We may rely on consent where appropriate, including for certain:
direct marketing communications;
non-essential cookies or similar technologies;
optional data uses.
Where processing is based on consent, you may withdraw that consent at any time.
Withdrawal does not affect processing that was lawful before consent was withdrawn.
5.5 Vital interests
In exceptional circumstances, we may process information where necessary to protect
someone’s life or physical safety.
5.6 Recognised legitimate interests or other lawful bases
Where applicable under current data-protection law, we may rely on another lawful basis
made available by legislation, including recognised legitimate interests, where its legal
requirements are satisfied.
6. Specific Ways We Use Personal Information
We may use personal information to:
provide and operate the Website;
register and administer accounts;
authenticate users;
publish authorised agent or agency profiles;
publish authorised property information;
respond to property enquiries;
identify potentially relevant properties;
send enquiries to relevant property providers;
arrange or facilitate viewings;
manage offers and negotiations;
administer property instructions;
communicate with buyers, sellers, landlords, agents and other parties;
process investment enquiries;
assess whether a particular opportunity or discussion may be appropriate;
organise consultations;
manage partner referrals;
refer customers to requested service providers;
track the status of a lead or referral;
calculate or administer referral commissions where applicable;
perform identity and compliance checks;
prevent fraud and misuse;
maintain security;
handle complaints;
establish and defend legal rights;
maintain records;
improve our Website and services;
analyse Website performance;
personalise relevant Website content;
send marketing where permitted;
comply with law and regulatory obligations.
7. Property Enquiries and Sharing with Agents
When you enquire about a property, we may share relevant information with:
the listing estate agent;
the listing agency;
the commercial property agent;
the property owner;
the landlord;
the developer;
another authorized representative responsible for the property.
The information shared may include:
your name;
contact details;
property of interest;
nature of your enquiry;
viewing preferences;
relevant purchasing or renting information;
other information reasonably necessary to respond to your request.
The recipient may process your information as an independent controller under its own
privacy policy.
8. “Find Me a Property” Service
Where you ask us to help locate a property, we may use your requirements to:
search our own listings;
contact relevant agency partners;
contact property providers;
identify off-market or partner opportunities where lawfully available;
Communicate potential matches to you.
We will only share information reasonably necessary for the search and related enquiry.
9. Investment Enquiries
Information provided through an investment enquiry may be used to:
understand your objectives;
arrange a consultation;
assess what type of discussion may be appropriate;
conduct legal or compliance checks;
determine whether information about a particular opportunity can lawfully be
provided;
prepare or administer separately agreed-upon documentation;
Maintain records of communications.
An investment inquiry is not the same as entering into an investment.
If a separate investment, loan, joint venture, special purpose vehicle, or other arrangement
is entered into, additional privacy information may be provided where necessary.
10. Partner and Professional-Service Referrals
Where you request a service from a third-party partner, we may share relevant information
with the selected provider.
This may include:
your name;
contact information;
property address;
service required;
project information;
preferred timeframe;
documents or photographs you asked us to pass on.
The receiving provider will generally be responsible for its own processing of your
information once received and should provide its own privacy information where required.
We may record:
the fact of the referral;
the partner involved;
referral progress;
whether a transaction completed;
commission or referral information.
11. Who We May Share Personal Information
With
Where lawful and necessary, we may share information with:
estate agents;
estate agencies;
commercial property agents;
developers;
landlords;
sellers;
property owners;
prospective buyers or tenants where appropriate;
mortgage advisers;
finance providers;
solicitors and conveyancers;
accountants;
tax advisers;
surveyors;
valuers;
architects;
builders and construction companies;
plumbers and electricians;
property managers;
insurers;
professional advisers;
identity-verification providers;
fraud-prevention providers;
compliance and screening providers;
CRM providers;
Website hosting providers;
cloud-storage providers;
email providers;
telephone and communication providers;
WhatsApp or other messaging providers;
analytics providers;
advertising providers, where permitted;
payment processors;
IT and cybersecurity providers;
consultants and contractors;
insurers;
auditors;
prospective purchasers or investors in our business as part of a legitimate corporate
transaction;
courts;
law-enforcement bodies;
regulators;
government bodies;
HMRC;
other parties where required or permitted by law.
We do not sell personal information as a standalone commodity.
The fact that we may receive a referral fee or commission from a partner does not mean that
we sell your personal information.
12. Data Processors and Other Controllers
Some organizations process personal information only on our instructions and act as
processors.
Other organizations determine their own purposes and means of processing and act as
separate controllers.
Where appropriate, we use contractual and organizational measures to govern processing
relationships.
13. International Transfers
Some of our service providers may store or process personal information outside the United
Kingdom.
Where personal information is transferred internationally, we will take steps required by
applicable data-protection law.
Depending on the destination and circumstances, this may include relying on the following:
UK adequacy regulations;
legally recognised contractual safeguards;
another lawful transfer mechanism; or
a specific legal exception where applicable.
We may also carry out appropriate transfer assessments where required.
You may contact us for further information about safeguards relevant to your personal
information.
14. How Long We Keep Personal Information
We do not keep personal information for longer than reasonably necessary for the purposes
for which it was collected, subject to legal, regulatory, contractual, and legitimate business
requirements.
Retention periods may vary.
As a general working framework, we may retain:
General enquiries
Normally for up to 24 months after the last meaningful interaction, unless there is a reason
to retain them for longer.
Property enquiries and viewing records
Normally for up to 6 years after the relevant inquiry or transaction ends where reasonably
required for legal, complaint, or business-record purposes.
Contract and transaction records
Normally for up to 6 years after completion or termination, or longer where required by law
or justified by relevant limitation, tax, regulatory, or legal requirements.
Anti-money-laundering and compliance records
For the period required by applicable law and regulatory obligations.
Agent and partner account information
For the duration of the relationship and normally for an appropriate period after
termination to deal with legal, accounting, fraud, complaint, and business-record
requirements.
Marketing information
Until you withdraw consent, unsubscribe, or object, subject to retaining a minimal
suppression record where necessary to ensure we respect your preference.
Website security logs
For a period reasonably necessary for cybersecurity, fraud prevention, and system
administration.
Complaints and legal claims
For as long as necessary to investigate and resolve the matter and for an appropriate period
afterwards, having regard to potential legal claims and record-keeping obligations.
We may retain anonymized information for longer where it can no longer reasonably identify
an individual.
15. Data Security
We use reasonable technical and organizational measures designed to protect personal
information.
Depending on the nature of the information and systems used, measures may include the
following:
access controls;
password protection;
role-based permissions;
encrypted connections;
secure hosting;
security monitoring;
backups;
software updates;
staff or contractor access restrictions;
confidentiality obligations;
incident-management procedures;
appropriate provider due diligence.
No online system can be guaranteed to be completely secure.
You are responsible for keeping your own account credentials confidential.
16. Cookies and Similar Technologies
The website may use cookies and similar storage or access technologies.
These may include technologies required for:
security;
user authentication;
essential Website functions;
saving preferences;
analytics;
Website improvement;
advertising;
measuring campaign performance.
Where consent is legally required, we will request consent before using the relevant nonessential technologies.
Where current law permits particular technologies to be used without consent, we may rely
on the applicable legal exception provided its requirements are satisfied.
You will be provided with appropriate controls to manage relevant preferences.
The exact cookies and technologies used should be described through our cookie banner,
cookie settings tool, and/or separate cookie policy.
17. Direct Marketing
We may send relevant marketing communications where permitted by law.
Marketing may concern the following:
properties;
new listings;
commercial opportunities;
property services;
relevant events;
company news;
partner services;
other services we reasonably believe may be of interest.
Where consent is required, we will seek appropriate consent.
You may opt out of marketing communications at any time by:
using an unsubscribe link;
changing available account preferences;
contacting us at [MARKETING OR PRIVACY EMAIL].
Opting out of marketing does not prevent us from sending necessary non-marketing
communications relating to:
your account;
an active enquiry;
a transaction;
security;
legal matters;
a service you requested.
We may retain limited information on a suppression list to ensure that an opt-out continues
to be respected.
18. Social Media
If you interact with us through social media platforms, the relevant platform may
independently process personal information.
Your use of those services is also governed by the platform’s own privacy terms.
We may receive information that you
send directly to us;
make publicly available;
permit the platform to share it with us.
19. WhatsApp and Other Messaging Services
Where you choose to communicate through WhatsApp or another third-party messaging
service:
the service provider may process information under its own terms;
communications may be stored on relevant systems or devices;
You should avoid sending unnecessary sensitive information.
Where appropriate, we may transfer relevant information from messages into our CRM or
business records to manage your inquiry.
20. Automated Decision-Making and Profiling
We do not intend to make solely automated decisions that produce legal or similarly
significant effects on individuals unless:
there is a lawful basis.
applicable legal requirements are met; and
appropriate safeguards are provided.
We may use limited automation to
route enquiries;
categorise leads;
identify potentially relevant properties;
detect spam or suspicious activity;
organise communications;
support marketing analytics.
Where we introduce significant automated decision-making, we will provide any additional
information required by law.
21. Your Data-Protection Rights
Depending on the circumstances, you may have rights including:
Right of access
You may request confirmation of whether we process your personal information and
request access to it.
Right to rectification
You may ask us to correct inaccurate or incomplete personal information.
Right to erasure
You may ask us to delete personal information in circumstances where the law gives you
that right.
The right to erasure is not absolute.
Right to restriction
You may ask us to restrict certain processing in particular circumstances.
Right to object
You may object to certain processing, including processing based on particular legitimate
interests.
You have the right to object to direct marketing.
Right to data portability
In certain circumstances, you may request personal information you provided to us in a
structured, commonly used, and machine-readable format or ask for it to be transferred to
another controller where technically feasible.
Rights relating to automated decision-making
You may have rights and protections relating to significant automated decisions.
Right to withdraw consent
Where we rely on consent, you may withdraw it at any time.
Withdrawal does not affect processing that was lawful before withdrawal.
22. Exercising Your Rights
To exercise a data-protection right, contact:
Email: hello@zivacproperties.com
Address: 12 Bath Rd, Hounslow TW3 3EB
Please clearly explain:
who you are;
the right you wish to exercise;
the information or processing concerned.
We may request information reasonably necessary to confirm your identity.
We will respond within the period required by applicable law.
In certain circumstances, the law may allow us to:
extend the response period;
refuse a request;
restrict the information provided; or
charge a permitted fee.
Where applicable, we will explain our decision.
23. Data-Protection Complaints Procedure
If you believe we have not handled your personal information properly, you may make a
data-protection complaint directly to us.
You can complain by contacting:
Data Protection Complaints
Zivac Properties
Email: hello@zivacproperties.com
Address: 12 Bath Rd, Hounslow TW3 3EB
Please provide, where possible:
your name;
contact details;
a clear description of your concern;
relevant dates;
copies of relevant correspondence;
the outcome you would like us to consider.
We will:
1. provide a clear way for individuals to raise data-protection complaints;
2. acknowledge a data-protection complaint within 30 days of receiving it;
3. take appropriate steps to investigate the complaint without undue delay;
4. keep the complainant appropriately informed where necessary; and
5. Communicate the outcome of the investigation.
We may need to request proof of identity or authority where a complaint is made on behalf
of another person.
24. Complaints to the Information
Commissioner
You also have the right to raise concerns with the Information Commissioner’s Office
(“ICO”), the UK’s data-protection regulator.
We would appreciate the opportunity to address your concern directly first, but this does
not remove your right to contact the ICO.
Information Commissioner’s Office
Website: ico.org.uk
Telephone: 0303 123 1113
You should check the ICO’s current contact information directly before submitting a
complaint.
25. Children
The website and our property and commercial and investment-related services are
generally intended for adults.
We do not knowingly seek to collect personal information from children where it is
unnecessary.
If information relating to a child is processed in connection with a legitimate property
transaction or service, we will take appropriate care and apply applicable legal
requirements.
26. Third-Party Websites
The website may link to third-party websites.
Those organizations may process your information under their own privacy policies.
We are not responsible for the privacy practices of independent third-party websites.
You should review their privacy information before providing personal information.
27. Business Transfers
If our business or assets are
sold;
reorganised;
merged;
transferred;
financed;
acquired;
Personal information may be disclosed to relevant professional advisers, prospective
transaction parties, and the acquiring or reorganizing entity where lawful and reasonably
necessary.
Appropriate confidentiality and data-protection measures will be considered.
28. Legal Claims, Authorities and Regulatory
Disclosures
We may process or disclose personal information where reasonably necessary to:
comply with law;
respond to court orders;
respond to legally valid regulatory or law-enforcement requests;
prevent or investigate fraud;
protect individuals;
establish, exercise or defend legal claims;
protect our legal rights;
comply with anti-money laundering and other compliance duties.
We may not always be legally permitted to notify an individual about a particular disclosure.
29. Changes to This Privacy Policy
We may update this Privacy Policy to reflect:
changes in law;
regulatory guidance;
changes to our business;
changes to our technology;
changes to our services;
changes to the organizations with which we work.
The latest version will be published on the website with an updated “Last updated” date.
Where a change materially affects how we use personal information, we will take reasonable
steps to bring the change to the attention of relevant individuals where required.
30. Contact Us
For privacy questions, rights requests, or data-protection concerns, contact:
Zivac Properties
ZIVAC PROPERTIES LTD
12 Bath Rd, Hounslow TW3 3EB
Privacy email: hello@zivacproperties.com
Telephone: 07466412665
ICO registration number:
For data protection complaints:
Email: hello@zivacproperties.com