Privacy Notice.

This privacy notice is issued by AAPS Properties Ltd, a company registered in England and Wales under company number 14573758, with its registered office at 16 South End, Croydon, Surrey, CR0 1DN ("AAPS", "we", "us").

AAPS is the data controller for the personal data described in this notice. We are registered with the UK Information Commissioner's Office where required under the Data Protection (Charges and Information) Regulations 2018.

If you have any questions about this notice, please contact us at privacy@aapsproperties.co.uk.

We collect and process the following categories of personal data:

• Identification & contact data — name, email address, telephone number, postal address, country of residence.
• Engagement data — details of your enquiry, project location, scope of intended work, principal contact at the property, professional advisors.
• Identity verification data — passport or government-issued identification, proof of address, beneficial ownership information (collected only where required for anti-money-laundering or contractual due diligence).
• Financial data — bank account details, payment records, invoices (in respect of engaged clients only).
• Technical data — limited website analytics (described in the Cookie Notice).

We do not knowingly collect data relating to children. We do not process special category personal data unless specifically necessary and with explicit consent.

We process personal data on the following lawful bases:

• Performance of a contract — to respond to enquiries, prepare engagement proposals, and deliver project management services to engaged clients.
• Legal obligation — to comply with anti-money-laundering, tax, accounting and other UK statutory obligations.
• Legitimate interests — to maintain records of past and prospective engagements, manage our practice and ensure security of our systems, where such processing is proportionate and does not override your rights.
• Consent — for any marketing communications (we currently do not undertake outbound marketing), and for non-essential cookies.

We share personal data only where necessary and on a confidential basis, with:

• Appointed consultants and contractors on your project, where you have authorised disclosure (architects, engineers, contractors, legal and tax advisors).
• Professional advisors to AAPS — our accountants, auditors, legal advisors, insurance brokers and underwriters, all under written confidentiality obligations.
• Service providers — email hosting, cloud document storage, accounting software, all selected with regard to security and UK GDPR compliance.
• Authorities — where required by law (HMRC, the Information Commissioner, court orders, anti-money-laundering authorities).

We do not sell personal data. We do not transfer personal data outside the United Kingdom or European Economic Area without an appropriate transfer mechanism in place (UK adequacy regulations, standard contractual clauses or equivalent).

We retain personal data only for as long as necessary:

• Enquiries that do not progress to engagement — 24 months from the date of last contact, then deleted.
• Engaged client records — six years following the end of the engagement, in line with the Limitation Act 1980 and our professional indemnity insurance requirements.
• Anti-money-laundering records — five years from the end of the business relationship, as required by the Money Laundering Regulations 2017.
• Accounting records — six years, as required by HMRC.

Under the UK GDPR you have the right to:

• Request access to the personal data we hold about you.
• Request rectification of inaccurate or incomplete data.
• Request erasure where there is no compelling reason for continued processing.
• Object to processing based on legitimate interests.
• Request restriction of processing in certain circumstances.
• Request portability of data you have provided to us, in a structured machine-readable format.
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact privacy@aapsproperties.co.uk. We will respond within one month.

If you believe we have failed to handle your data lawfully, you have the right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk or by telephone on 0303 123 1113. We would ask that you contact us first so we have an opportunity to resolve the matter.

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction. These include encrypted storage, access controls, multi-factor authentication on relevant systems, and staff confidentiality obligations.

We may update this notice from time to time. The current version is always available at this address with the last-updated date shown at the top.