BBG Real Estate London Ltd

Effective Date: 11 September 2026
Review Date: 11 September 2027
Version: 2.4

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1. Introduction

BBG Real Estate London Ltd (“BBG”, “we”, “our”, or “us”) is committed to protecting and respecting the privacy of our clients, prospective clients, landlords, tenants, investors, occupiers, suppliers, professional advisers, website users and other individuals whose personal information we process.

This Privacy Notice explains how we collect, use, disclose, retain and protect personal information in accordance with:

• UK General Data Protection Regulation (“UK GDPR”);
• Data Protection Act 2018;
• Data (Use and Access) Act 2025;
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended);
• HMRC Guidance for Estate Agency Businesses;
• RICS Professional Standard: Countering Bribery, Corruption, Money Laundering and Terrorist Financing;
• Applicable UK sanctions legislation and related regulatory requirements.

This Privacy Notice also explains the rights available to individuals under UK data protection legislation.

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2. Data Controller

BBG Real Estate London Ltd

68 King William Street
London EC4N 7HR

Email: compliance@bbg.co.uk

BBG is the Data Controller responsible for determining the purposes and means by which personal information is processed.

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3. Scope

This Privacy Notice applies to personal information processed in connection with:

• Commercial property agency instructions;
• Landlord and tenant transactions;
• Leasing and occupational agency;
• Investment acquisitions and disposals;
• Property marketing campaigns;
• Valuation and advisory assignments;
• Client onboarding and due diligence;
• Anti-money laundering checks;
• Supplier management;
• Recruitment activities;
• Website and digital communications.

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4. Personal Information We Collect

Depending upon the nature of our relationship with you, we may process the following categories of information.

Identity Information

• Full name
• Date of birth
• Nationality
• Passport or driving licence details
• Proof of address
• Beneficial ownership information
• Companies House information

Contact Information

• Address
• Telephone number
• Email address
• Business contact details

Employment and Business Information

• Employer details
• Position held
• Professional qualifications
• Corporate affiliations

Financial Information

• Bank account details
• Source of funds information
• Source of wealth information
• Transaction histories
• Credit and financial references

Property Information

• Ownership interests
• Leasehold interests
• Property requirements
• Property transaction records
• Occupation details

Compliance Information

• AML verification records
• Sanctions screening results
• Politically Exposed Person (PEP) checks
• Adverse media screening
• Risk assessments

Technical Information

• IP addresses
• Website usage data
• Browser information
• Device identifiers
• Cookie data

Security Information

• Visitor records
• CCTV images where applicable
• Building access records

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5. How We Collect Information

We obtain information:

Directly From You

Through:

• Property enquiries;
• Instruction letters;
• Meetings and correspondence;
• Website forms;
• Marketing subscriptions.

From Third Parties

Including:

• Solicitors;
• Property managers;
• Surveyors;
• Landlords;
• Tenants;
• Purchasers;
• Vendors;
• Lenders;
• Professional advisers.

From Public Sources

Including:

• Companies House;
• HM Land Registry;
• Planning authorities;
• Court and insolvency records;
• Sanctions lists;
• Publicly available media sources.

Through Compliance Screening Providers

For the purpose of:

• Identity verification;
• AML compliance;
• Fraud prevention;
• Sanctions screening.

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6. Commercial Property Data Flows

As part of normal commercial property transactions, BBG may process information relating to:

Landlords

Including:

• Property ownership details;
• Corporate structures;
• Banking arrangements;
• Letting instructions.

Tenants and Occupiers

Including:

• Contact information;
• Lease information;
• Business activities;
• Financial covenant information.

Investors

Including:

• Acquisition criteria;
• Investment structures;
• Due diligence materials;
• Funding information.

Purchasers and Vendors

Including:

• Transaction documents;
• Professional adviser details;
• Identity verification records;
• Financial information.

Processing of these data flows is necessary for the delivery of professional real estate services and regulatory compliance obligations.

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7. Purposes of Processing

We process personal information for the following purposes.

Delivery of Professional Services

Including:

• Agency services;
• Acquisition and disposal instructions;
• Leasing assignments;
• Property marketing;
• Valuation services;
• Client relationship management.

Compliance With Legal Obligations

Including:

• AML checks;
• Counter-terrorist financing measures;
• Sanctions screening;
• Fraud prevention;
• Law enforcement requests;
• Regulatory reporting.

Legitimate Business Interests

Including:

• Business development;
• Service improvement;
• Risk management;
• Record management;
• Website administration.

Marketing Activities

Including:

• Property opportunities;
• Market commentary;
• Research reports;
• Event invitations.

You may unsubscribe from marketing communications at any time.

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8. Lawful Bases for Processing

BBG relies on one or more of the following lawful bases under Article 6 UK GDPR:

Contract

Processing required to perform a contract or take steps before entering into a contract.

Legal Obligation

Processing necessary to comply with legal and regulatory requirements.

Legitimate Interests

Processing necessary for our legitimate interests, including management and operation of our business, provided those interests are not overridden by your rights.

Consent

Where required by law, we will obtain consent before processing personal information for specific purposes.

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9. Anti-Money Laundering and Counter-Financial Crime Processing

As a commercial real estate agency business, BBG is subject to statutory obligations requiring the collection and verification of personal information.

We may:

• Verify identity;
• Verify beneficial ownership;
• Conduct sanctions screening;
• Perform PEP screening;
• Verify source of funds;
• Verify source of wealth;
• Monitor ongoing business relationships;
• Record and investigate suspicious activity.

Failure to provide information required for AML purposes may prevent us from acting on your behalf.

BBG processes such information pursuant to legal obligations and the public interest in preventing financial crime.

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10. Disclosure of Personal Information

Personal information may be disclosed to:

• Solicitors;
• Surveyors;
• Property consultants;
• Landlords;
• Tenants;
• Purchasers;
• Vendors;
• Lenders;
• Professional advisers;
• Regulatory authorities;
• HMRC;
• National Crime Agency;
• Law enforcement agencies;
• IT service providers;
• Secure cloud hosting providers.

Information is disclosed only where lawful and proportionate.

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11. International Transfers

Where personal information is transferred outside the United Kingdom, appropriate safeguards will be implemented, including:

• UK adequacy regulations;
• International Data Transfer Agreements (IDTAs);
• Approved contractual safeguards.

We will take reasonable steps to ensure equivalent protection is maintained.

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12. Data Security

BBG implements appropriate technical and organisational measures designed to protect information against:

• Unauthorised access;
• Loss;
• Destruction;
• Alteration;
• Disclosure.

Measures may include:

• Access controls;
• Multi-factor authentication;
• Encryption;
• Secure backups;
• Staff training;
• Compliance monitoring.

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13. Data Retention

Information will not be retained longer than necessary.

Typical retention periods include:

Retention periods may be extended where litigation, regulatory enquiries or legal obligations require.

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14. Data Subject Rights

Subject to legal limitations, individuals may have the right to:

• Access personal information;
• Rectify inaccurate information;
• Erase personal information;
• Restrict processing;
• Object to processing;
• Data portability;
• Withdraw consent;
• Challenge automated decision-making where applicable.

Requests should be submitted to:

compliance@bbg.co.uk

We may request proof of identity before responding.

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15. Complaints

Individuals are encouraged to contact BBG first if they have concerns regarding personal information processing.

They also have the right to complain to:

Information Commissioner’s Office (ICO)

Website: Information Commissioner’s Office

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16. Cookies and Website Analytics

Our website may use cookies and analytics technologies to:

• Maintain website functionality;
• Improve user experience;
• Monitor website performance;
• Understand visitor behaviour.

 

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17. Special Category and Criminal Offence Data

Where necessary for AML compliance, sanctions screening, fraud prevention or legal claims, BBG may process limited categories of sensitive personal information in accordance with applicable legal requirements and Schedule 1 of the Data Protection Act 2018.

Such processing is subject to enhanced safeguards and restricted access controls.

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18. Regulatory Commitment

BBG is committed to maintaining data governance standards that support:

• UK GDPR compliance;
• Data Protection Act 2018 compliance;
• Data (Use and Access) Act 2025 compliance;
• HMRC AML obligations;
• RICS professional and ethical standards;
• Prevention of money laundering, terrorist financing and sanctions evasion;
• Protection of clients, counterparties and the wider property market.

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Approved by: Tom Boggis, Managing Director
Policy Owner: Sarah Boggis, Compliance Lead
Version: 2.4
Next Review Date: 11 September 2027