Privacy & Cookies Policy

1. Introduction

Our use of your personal data will be governed by this Privacy Notice.

Imperia Broker Ltd is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the EU GDPR, and the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, and your personal information will only be shared with others in accordance with this Privacy Notice.

This Privacy Notice explains:
- What personal information is
- How we collect your personal information
- The types of personal information we collect
- How we use your personal information
- The legal basis for processing your personal information
- How we share your personal information
- How long we keep your personal information
- How we keep your personal information secure
- Overseas transfers of your personal information
- Your rights in relation to your personal information
- How to make complaints and how to contact us

If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.

2. What is personal information

Personal information is any information that tells us something about you. This could include information such as your name, contact details, date of birth, bank account details, or any information about your needs or circumstances which would allow us to identify you.

Some personal information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions, and sexual orientation. This information is more sensitive, and we need to have further justifications for collecting, storing, and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.

Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.

3. What personal information do we collect?

We will collect your full name and contact details (such as phone number, email address, and postal address) from you whenever you engage with us.

In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

We will also confirm whether you have any relatives or close connections working at Imperia Broker Ltd so that we can consider potential conflicts of interest and, if identified, manage these in accordance with our statutory and regulatory obligations.

Depending on the service that we provide to you (or on your behalf), we may also collect additional personal information as detailed below:

Buy, Sell, Let, Rent

If you are buying, selling, or letting a property through us:
- We will collect a contact telephone number to get in touch with you about organising viewings and updating you on any offers received or rental applications for your property.
- Where you have enquired about buying a specific property, we will use your contact details to respond, which may include us sending you alternative properties to help with your search.
- Where you are not the legal owner of the property, we will request details from you as to your ability to sell or let the property such as a Power of Attorney, Guardianship Order, or Grant of Probate.
- Where you engage with Imperia Broker Ltd, we may collect information required to identify you to meet anti-money laundering and counter-terrorist financing requirements. If we are dealing with an entity such as a company, trust, or charity, we may need to obtain personal information for the beneficiaries of the entity and those in a position of control. This will include, but is not limited to, identity and address documents.
- We may also need to collect information on other individuals who have an interest in the property who are not considered to be our customers.
- We will collect your bank account details to arrange onward payment of rent due to you.
- Where we are working alongside third parties such as solicitors, developers, joint or multi agents, we may need to share these documents on the basis of legitimate interests.
-If you wish to purchase a property we are listing for sale and you have specifically provided us with these, we will collect personal information relating to any specific access requirements you may have in relation to a property so that we can find one suitable for your needs.

If you wish to rent a property we are listing:
- Where you have enquired about renting a specific property, we will use your contact details to respond, which may include sending you alternative properties to help with your search.
- We will collect your bank or building society details to manage tenancy deposits and set up rental payments.
- If you are a tenant renting under the 'Right to Rent' scheme (UK), we will collect details of your biometric residence card, your immigration status document and/or your birth certificate to carry out required checks.
- We may also need to collect specific identity documents from you for the purpose of preventing and detecting crime, fraud, or money laundering.

Property Management

- Where we engage with you to manage property on your behalf, we will ask for additional emergency contact information.
- Where you engage us for portfolio management services, we will share your personal information with third-party lenders as necessary to fulfil our obligations and properly manage your property investments.
- Where you are a tenant in a building managed by Imperia Broker, we may need to share your personal information with the property owner, but will only do so having considered your rights first.
- Where we operate CCTV in a property, we may capture your image which would constitute your personal data.

Investment Management

Where you engage with Imperia Broker Ltd or one of its subsidiaries as an individual investor, we will collect information required to identify you to meet anti-money laundering and counter-terrorist financing requirements. If the investor is an entity such as a company, trust, or charity, we may need to collect personal information about the controllers and beneficiaries of the entity.

Property Management

If you subscribe to receive research, news, or market updates from us, then in addition to the above, we will collect details about the sector in which you work and the type of content you would like to receive.

4. How we use your personal information

What is the legal basis of our data processing?

Under data protection legislation, we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases:
- For employment-related purposes.
- Where we need information to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where the processing is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests.

This includes:
- Processing that is necessary for us to promote our business, brands, and products and measure the reach and effectiveness of our campaigns — including sending marketing information from time to time after you have engaged us or where you have expressly indicated consent.
- Processing necessary to improve our knowledge of the real estate and education sectors — including market analysis and research to better understand trends.
- Processing necessary to operate administrative and technical aspects of our business efficiently and effectively.

In limited circumstances, we may also rely on:
- Protection of your interests (or someone else's).
- Public interest or official purposes.

We may process special categories of personal information or criminal conviction data only with your explicit consent or as otherwise permitted by law.

5. How we keep your information secure

The security of your information is very important to us. We have measures in place designed to prevent unauthorised access, including:
- Secure client management systems with restricted access.
- Locked storage for hard copy documentation.
- Data hosted in secure data centres with restricted access and robust protections.
- Staff training on data protection and confidentiality.

6. How long we keep your personal information

The period for which we keep your personal information depends on the type of service you have requested. The retention period may be longer where required by statutory or regulatory obligations, or where needed to retain information in case of a legal claim.

7. Overseas transfers of your personal information

We may transfer, store, or process your personal information in locations outside the UK, EU, or UAE. Where such countries do not offer an equivalent level of protection, we will ensure appropriate safeguards are in place, such as:
- Transfers to countries with an adequacy decision.
- Standard Contractual Clauses (SCCs) approved by the EU/UK.
- Binding Corporate Rules.

8. Your rights in relation to your personal information

You have the right to:
- Be informed about how we use your personal information.
- Obtain access to your information.
- Request correction of inaccurate or incomplete information.
- Request erasure of your data where applicable.
- Restrict processing in certain cases.
- Request a copy of data you have provided in a portable format.
- Object to processing based on legitimate interests.
- Not be subject to wholly automated decisions producing legal or similarly significant effects.

If you would like to exercise any of these rights, please contact info@imperiabroker.com.

We will keep a record of your request and our response for compliance purposes.

9. Complaints and Contact Details

Complaints

If you have any complaints about the way we use your personal information, please contact the Customer Relations Officer at info@imperiabroker.com.

Contact details

If we cannot resolve the issue, you have the right to complain to the relevant data protection authority in your country — such as the Information Commissioner’s Office (UK), EU supervisory authority, or UAE Data Office.

— Imperia Broker