Privacy Policy

Details of how we use and protect your personal information

Background

Sourcing Investments Limited (“SI”) processes personal information to enable us to provide services as a marketplace for investors seeking access to high quality property investment opportunities and the provision of tools to enable the efficient and secure execution of preferred investments. SI is subject to data protection legislation and regulation, and the following Privacy Policy aims to outline how we manage the data we hold. SI is registered as a Data Processor with the ICO, under registration reference number ZA175319. SI has requested to the ICO to be changed to Data Controller status. SI undertakes to comply with the General Data Protection Regulation (GDPR) which came into effect on 25th May 2018. By requesting or using our services you accept and consent to our use of your personal data as outlined in this policy. If you disagree with any part of these terms and conditions, please do not use our website. The Board of SI takes Data Protection seriously and works to ensure that a culture and awareness of the importance of Data Protection flows through our business. This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be managed and processed by us.

Your Personal Data

We may collect and process the following information about you that you provide to us: You may provide us with information by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register for an account or subscribe with us, when you contact sourcing agents via forms or through the Business Conversation Area made available on our website, or via a survey, feedback forms and/or when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number and other details. When you visit our website or use our mobile app we may automatically collect information about your computer or mobile device, including your IP address, information about your visit, your browsing history, and how you use our website or app. This information may be combined with other information you provide to us, as described above. We primarily use personal information about you in connection with the following purposes:
  1. To provide you with the information, products and services that you request from us;
  2. To provide detail on potential property investments to you;
  3. To enable you to participate in interactive features of our service when you choose to do so
We will also use your personal data for marketing purposes to provide you with information about goods or services that may interest you, including both SI goods and services, as well as those from carefully selected third parties where we think these are likely to be useful to you, specifically with regards to your property investing activities. We do not permit advertising to you which is not relevant to your property investing activities. We will also record data to measure or understand the effectiveness of the marketing that we serve to you, which may be based on your activity on our website. We will also use your data to update you about service improvements or changes to services, account management matters, to administer our website and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We will also receive and store data from analytics providers and search engine providers that assist us in the improvement and optimisation of our website. Your personal information is generally shared in a form that does not directly identify you.

Sharing your Personal Data

We may also share your personal information with third parties in the following circumstances: When investors and sourcing agents connect in the Business Conversation Area, details about the other party will provided within the conversation area to the other party. Upon receipt of your personal information, the relevant third party is the data controller and their use of your information will be governed by their own terms of use and privacy policy. Information is only shared with Sourcing Agents when you have directly expressed an interest in a sourcers investment project and therefore you willingly consent to our connecting you to the sourcer via shared personal data. SI provides personal data to third party contractors to enable the function of the site and services. SI does not permit the use of the data to be sold, reused or forwarded. SI uses third party service providers of good reputation and takes steps to ensure that they themselves have adequate data protection policies in place and take data protection seriously. Written contracts are in place with such service providers. Although the Sourcing Investments website includes links providing direct access to other internet resources, including websites, Sourcing Investments is not responsible for the accuracy or content of information contained in these websites. SI cannot be responsible for the data protection provided by such sites and will only provide personal data to such sites if requested to do so by our users. Users should make their own enquiries and assessment of the adequacy of data protection provided by those sites.

Disclosure by Law

SI will make available personal information, to the extent it is required to do so, to any competent and duly authorised legal or regulatory body, including for example HMRC with regards to matters of taxation.

Where we store your personal information

SI stores its data on both its own secure internal servers and also within the secured hosting infrastructure provided by Amazon Web Services – a hosting business of considerable reputation. The information that we collect from you may be transferred to, and stored, in a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for one of our suppliers. The laws in some countries may not provide as much legal protection for your information as in the EEA. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Security of Your Data

We take security of the site and data security very seriously – not least as offering a safe and secure method to do business is a key selling point of our business and therefore the reputational implications of a security breach or data breach are at the forefront of our minds. All data transfer takes place securely and in an encrypted fashion. SI and its website developers adopt best practices and industry standards which are proportional to a business of this size and relevant to the nature of the business we conduct. All computer access is secured with strong password authentication and access to shared network drives is limited to only authorised staff. Passwords are changed periodically. Data is stored on secure and encrypted hosted infrastructure. All computers have anti-virus & anti-malware software installed which is updates continually. Where we have given you, or where you have chosen, a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Cookies

The SI website uses Cookies, these are mandatory for all users. Details of the cookies we use can be found here.

Business Conversation Area

A unique feature of the SI site is the Business Conversation Area, the primary purpose of which is to record conversations between investors and sourcers or other service providers. The aim is to provide a complete record of the conversation in the event of any problem or dispute which requires resolution. Data Protection Legislation permits a user to request the deletion of certain of their data. With regards to the Business Conversation Area, conversations will not be deleted if requested by the user. This is to protect both parties to the conversation to ensure a record of conversations is kept supporting any claim in the event of dispute. All users of the Business Conversation Area agree, that by their use of the service, they consent to the continued storage of all business conversations in the Business Conversation Area, for any period which is considered to be reasonable by SI.

Your Rights

You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking or unchecking certain boxes on the forms we use to collect your data, unsubscribing via any marketing emails we send, amending your details in the my account area or requesting as such at admin@sourcinginvestments.co.uk The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. In most cases we will not charge a fee for access. If the request is manifestly unfounded or excessive, or if an individual requests further copies of their data following a request, we may charge a reasonable fee for the administrative costs of complying with the request. Under new GDPR laws, individuals have the right to be “forgotten.” If requested in writing by you, we will delete all information on you from our records, both electronic and paper, but please note that will mean we will be unable to contact you in the future about relevant investment opportunities. We can delete the information we store on your if requested as far as reasonably practical. This can include your personal data as used day to day within SI but cannot for practical reasons be deleted from the daily compressed back up files we make daily to protect our system. Please refer to the Business Conversation Area section above regarding our policy on Business Conversation storage.

Confidentiality

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Policy. We will maintain the confidentiality of and protect your information in accordance with our Privacy Policy and all applicable laws.

Children

Our Website is not directed at, nor do we knowingly collect personal data from, people under the age of 18.

Definitions

The term ‘Sourcing Investments Ltd’ or ‘us’ or ‘we’ or ‘SI’ refers to the owner of the website whose registered office is: C/O Bvn Partners LLP, Innovation Warehouse 1st Floor, East Poultry Avenue, London, Greater London, England, EC1A 9PT. Our company registration number is 09920397. The term ‘you’ or ‘Investor’ or ‘Sourcer’ refers to the users or viewers of our website.

Changes to this Privacy Policy

From time to time, we may change this Policy. Changes to this Policy are effective as of the effective date listed above and indicates the last time this Policy was revised or materially changed. Your continued use of this website indicates your consent to the changes to this Policy.

Contact

If you have any questions or queries about the information contained in this Privacy Policy, or wish to update your personal data, or to request a copy of what data SI holds about you or any other matters regarding Data Protection please contact admin@sourcinginvestments.co.uk

E&OE. Updated 04.06.2018