This document tells you about our policies:

• Who we are
• Our Products & Services
• Online Payments & Costs
• Online Refund, Return & Cancellation
• Privacy, Security & Disclosure
• Complaints

Who we are

“We” are Residential Property Investments Ltd trading as Complete RPI (Company number 04192464) and our company registration address is Unit 1 Complete RPI HQ, Nankeville Court Guildford, Road Woking Surrey GU22 7NJ, United Kingdom. We can also be contacted at [email protected]. Our VAT number is GB 775452405. We are registered under the Data Protection Act 1998, number Z8897149.

Our Products & Services

“We” provide:

• Private Investment
• Accounting Services
• Residential Lettings
• Corporate Investment
• Residential Sale Management
• Residential Property Investment
• EPC’s & Conveyancing Independent Solicitors
• Mortgage & Financial Services via Independent Financial Advisors
• Other property related services including Design & Refurbishment

Privacy, Disclosure & Security Policy

Complete RPI understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.completerpi.com (“our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of our Site

“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in section 11, below;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our” means Residential Property Investments Ltd , trading as Complete RPI, a limited company registered in England under company number 04192464 whose registered address is RPI House, 53 Stepgates, Chertsey, Surrey KT16 8HT.

2. Who Are We

2.1 Our Site is owned and operated by Complete RPI, a limited company registered in England under company number 04192464 whose registered address is RPI House, 53 Stepgates, Chertsey, Surrey KT16 8HT.

2.2 Our VAT number is GB775452405.

2.3 Our Data Protection Officer is Ms Jackie Walshe (Finance Director) who can be contacted by email at [email protected], by telephone on +44 1932 56 88 77, or by post at the above address.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

4.1.1 The right to be informed about our collection and use of personal data;

4.1.2 The right of access to the personal data we hold about you (see section 10);

4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 12);

4.1.4 The right to be forgotten – You can request that we erase your personal information in the following circumstances:

If we are continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected

If we are relying on consent as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing

If the personal information has been processed unlawfully (ie in breach of the requirements of the data protection legislation)

If it is necessary to delete the personal information to comply with a legal obligation

You can ask us to restrict our data processing activities when you consider that:

Personal information is inaccurate

Our processing of your personal information is unlawful

Where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim

Where you have raised an objection to our use of your personal information

4.1.5 Object to our processing of your personal information where we are relying on legitimate interests to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 12 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of our services, we may collect some or all of the following personal and non-personal data:

5.1 Name

5.2 Date of birth

5.3 Gender

5.4 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)

5.5 Business/Company name

5.6 Contact information such as email addresses, home address and telephone numbers

5.7 Emergency contact details

5.8 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.

5.9 If you are a tenant renting under the “Right to Rent” scheme we will collect details of your Biometric residence card, your immigration status document and/or your birth certificate to carry out our required checks under this scheme.

5.10 Demographic information such as postcode

5.11 Financial information such as credit/debit card numbers and bank account details

5.12 IP address

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under GDPR at all times. For more details on security see section 7, below.

6.2 We use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

6.2.1 Providing and managing your Account

6.2.2 Providing and managing your access to our Site

6.2.3 Supplying our services to you (please note that we require your personal data in order to enter into a contract with you). If you are purchasing a property we are acting as agents for the sale of or selling a property through us we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase.

If you are renting a property for which we are acting as letting agents, we will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property.

Where we are managing property on your behalf as a landlord, or managing a property of which you are a tenant, we may need to pass your personal information from time to time on a third party contractors whom we have engaged to carry out maintenance on your properties.

6.2.4 Personalising and improving our services and features to you

6.2.5 Replying to emails from you

6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email or telephone with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retrain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

7.2 Your data will only be stored in the UK.

7.3 We follow strict security procedures to ensure that your personal information is not damaged, destroyed, or disclosed to a third party without your permission and to prevent unauthorised access to it.

7.4 Whilst we store our data in the UK we will, with your consent, transfer your data to third countries if required. For example, if you are an overseas resident we will email you there. You must be aware that some third countries do not offer the same degree of protection as the UK and in particular email correspondence might be subject to government surveillance or other interception or monitoring. We are not responsible for data protection in third countries.

8. Other Uses Of Your Data

8.1 We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.

8.2 Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.

8.3 We may aggregate the information to identify patterns which we can use in our marketing and help us develop, administer, support and improve our services.

8.4 We may share your personal information with any person working within Residential Property Investments Limited on a need to know basis to ensure we are able to perform our obligations to you.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will be transferred under the terms of this Privacy Policy. The new owner will be permitted to use that data only for the same purposes for which it was originally collected by us.

10. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held) under GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at [email protected], or using the contact details below in section 12.

11. Our Use of Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

11.1 All Cookies used by and on our Site are used in accordance with current Cookie Law.

11.2 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

11.3 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

12. Contacting Us

If you have any questions about our Site or this Privacy Policy, please contact us by email at [email protected], by telephone on +44 1932 56 88 77. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.