Privacy Policy

Last updated: 1 December 2025

1) Who we are

This is the Privacy Policy of SW Partners In Property Ltda property investment company registered in England and Wales under company number 16034150 with registered office at 9 Auster Close, Christchurch, England, BH23 4JR

We are the data controller of personal data processed through our website https://sw-pip.co.ukand in connection with our services (e.g., investor relations, acquisitions, disposals, joint ventures, and property management support where applicable).

• ICO Registration Number: ZC023098
• Data Protection Contact / DPO: Sara Cromie
• Email: [info@sw-pip.co.uk]
• Postal: 9 Auster Close, Christchurch, England, BH23 4JR

2) The data we collect

We may collect and process the following categories of personal data:

• Identity & contact data: name, title, email, phone, address, date of birth, nationality, ID documents (e.g., passport/driver’s licence) for onboarding/AML.
• Professional data: role/title, company, regulatory status (e.g., HNWI/Sophisticated Investor statements), references.
• Financial & investment data: investment objectives, risk profile, source of funds/wealth, bank details for payments/distributions, tax      residence/status where required.
• Transaction data: enquiries, offers, Heads of Terms, NDAs/JVAs, deal notes, contracts, payment records.
• Compliance  data: KYC/AML results, sanctions checks, politically exposed person (PEP) screening, adverse media checks.
• Technical & usage data: IP address, device/browser type, pages visited,      referral sources, time on page, cookies and similar technologies.
• Marketing preferences: opt‑in/opt‑out status, communication channels and topics  of interest.
• Communications: emails, call notes, meeting notes, messages submitted via web forms or social media.

If you provide information about other individuals (e.g., co‑investors, referees, beneficial owners), you must ensure you have the legal right to share it with us.

3) How we collect data

• Direct: web forms, calls, emails, events, discovery calls, investor onboarding, due diligence, contract execution.
• Automated: cookies/analytics (see Section 10).
• Third parties: credit reference agencies, KYC/AML providers, identity      verification services, introducers/agents, public databases, professional      advisers, Companies House, sanctions lists, and where applicable, property portals or CRM tools.

4) Why we use your data (purposes) & lawful bases

We process personal data for the following purposes and legal bases:

Purpose: Responding to enquiries & providing services 

Examples:  Sending information, arranging viewings, evaluating opportunities 

Lawful basis: Contract or Legitimate interests (responding to requests)

Purpose: Investor onboarding & relationship management 

Examples:  Suitability checks, professional classification (HNWI/SI), investor updates

Lawful basis: Contract, Legitimate interests

Purpose: KYC/AML, anti‑fraud & regulatory compliance 

Examples:  ID verification, source of funds, sanctions/PEP screening 

Lawful basis: Legal obligation, Public interest (where applicable)

Purpose: Transaction execution 

Examples:  NDAs/JVs, offers, SPV participation, distributions 

Lawful basis: Contract

Purpose: Finance, accounting & tax 

Examples:  Invoicing, payments, financial records 

Lawful basis: Legal obligation, Contract

Purpose: Marketing & events 

Examples:  Newsletters, deal updates, thought leadership, invitations 

Lawful basis: Consent (for email/SMS under PECR) or Legitimate interests(B2B soft opt‑in where permitted)

Purpose: Analytics & site improvement 

Examples:  Measuring performance, preventing abuse 

Lawful basis: Legitimate interests

Purpose: Legal claims & risk management 

Examples:  Establish, exercise or defend legal claims 

Lawful basis: Legitimate interests, Legal obligation

Where we rely on consent, you can withdraw it at any time (see Section 12). Where we rely on legitimate interests, we balance those interests against your rights and freedoms.

5) Special category data

We do not intentionally collect special category data (e.g., health, religion). If exceptional circumstances require it (e.g., enhanced due diligence evidencing source of wealth that incidentally reveals sensitive data), we will apply appropriate safeguards and a relevant lawful basis.

6) Who we share data with

We may share limited necessary data with:

• Professional advisers: lawyers, accountants, auditors, tax advisers.
• KYC/AML & verification providers: identity checks, sanctions screening, credit reference agencies.
• Financial institutions & payment providers: banks, payment processors.
• Technology providers: website host, CRM, email service, analytics tools, document  e‑signature, cloud storage, communication platforms.
• Joint venture partners & counterparties: where required to progress a  deal, under NDA or contractual confidentiality.
• Regulators & authorities: HMRC, law enforcement, the ICO, the courts—where legally required.
• Buyers/sellers/agents:     limited data strictly necessary for transactions.

We require third parties to protect your data and process it only on our instructions where they act as processors.

7) International transfers

Some providers may be located outside the UK. Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or Addenda to EU SCCs, and implement additional measures where necessary. You can request details of applicable safeguards (subject to redactions for security/confidentiality).

8) Data retention

We keep personal data only as long as necessary for the purposes described and to meet legal, accounting or reporting requirements. Typical retention periods:

• Investor & transaction records: generally 6–10 years from the end of      the relationship/transaction (longer if required for legal claims).
• KYC/AML records: at least 5 years after the end of the      relationship/transaction (or longer where permitted/required).
• Marketing data: until you unsubscribe or your data becomes inactive for a  reasonable period.
• Website logs/analytics: typically 12–26 months, depending on provider settings.

We apply secure deletion or anonymisation once retention periods expire.

9) Security

We implement technical and organisational measures appropriate to risk, including access controls, encryption in transit (TLS), least‑privilege access, regular updates, staff training, and supplier due diligence. However, no system is entirely secure; please take care when sharing data over the internet.

10) Cookies & similar technologies

We use cookies and similar technologies to operate our site, remember preferences and analyse traffic.

• Strictly necessary cookies: required for core functionality (no consent needed).
• Analytics/performance cookies: help us understand usage and improve the site (consent may be required).
• Marketing/advertising cookies: used for remarketing or measuring campaign effectiveness (consent required).

When you first visit, we display a cookie banner allowing you to accept/reject non‑essential cookies and to manage settings. You can also adjust your browser settings to block cookies (this may affect site functionality).

See our Cookie Policy for details of providers, cookie names, purposes and durations. If you’d like, we can provide a dynamic, compliant cookie list integrated with your CMP.

11) Your rights (UK GDPR & Data Protection Act 2018)

You have the following rights, subject to conditions and exemptions:

• Access  to your personal data and a copy of it.
• Rectification of inaccurate or incomplete data.
• Erasure (“right to be forgotten”) in certain circumstances.
• Restriction of processing in certain circumstances.
• Data portability for data you provided to us, where processing is based on consent or contract and carried out by automated means.
• Object to processing based on our legitimate interests and to direct      marketing at any time.
• Withdraw consent where processing is based on consent (this won’t affect prior lawful processing).
• Complain to the ICO (see Section 13).

To exercise your rights, contact us at [info@sw-pip.co.uk]. We may need to verify your identity and we will respond within one month (or explain why an extension is needed).

12) Marketing communications

We may send you marketing (e.g., newsletters, deal updates, event invites):

• With your consent (e.g., web form opt‑in), or
• Under the soft opt‑in where permitted for similar products/services and you can opt out at any time.

You can unsubscribe using the link in our emails or by contacting [info@sw-pip.co.uk]. We do not sell your data to third parties for their own marketing.

13) Complaints

If you have concerns about our use of your personal data, please contact us first. You can also complain to the UK Information Commissioner’s Office (ICO):

• Website: https://ico.org.uk/
• Helpline:     0303 123 1113
• Address:     Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

14) Children

Our services and website are not intended for children. We do not knowingly collect data relating to anyone under 18. If you believe a child has provided us with personal data, please contact us.

15) Automated decision‑making & profiling

We do not use automated decision‑making that produces legal or similarly significant effects. We may use limited profiling (e.g., segmenting investors by risk appetite or preferences) to tailor communications. You can object to profiling used for direct marketing at any time.

16) Third‑party links

Our website may contain links to third‑party sites. We are not responsible for their privacy practices. Review their policies before providing personal data.

17) Updates to this policy

We may update this policy from time to time. We will post the updated version with a new “Last updated” date. For significant changes, we will notify you by email or prominent notice on our site.

18) Contact us

Questions or requests about this policy or your data rights:
Email: info@sw-pip.co.uk

Postal: 9 Auster Close, Christchurch, England, BH23 4JR