1. Who we are and when this policy applies
K&M Property Solutions Ltd (“K&M”, “we”, “us” or “our”) is the controller of the personal information described in this policy. We decide why and how that information is used, subject to applicable UK data protection and electronic communications law.
This policy applies when you enquire about or receive our property sourcing, deal packaging or introducer services; provide, market, fund or receive money connected with a property transaction; act for another person or organisation; supply services to us; visit our website; or contact us about a complaint or another matter.
Solicitors, lenders, brokers, estate agents, surveyors, contractors, banks and other independent organisations may act as separate controllers. Their own privacy policies apply to how they use information.
2. Information we collect
Identity and contact
Name, date of birth, address, email, telephone number, signature, photographs and identity-document details.
Business and ownership
Company, partnership or trust information, directors, owners, controllers, beneficiaries and authority to act.
Financial and transaction
Bank details, invoices, payments, proof of funds, source of funds or wealth, fees, refunds and Client Money records.
Property and service
Property addresses, criteria, budgets, strategy, viewings, offers, calculations, transaction progress and advisers.
Compliance and risk
Identity verification, sanctions and politically exposed person checks, adverse-media results, risk ratings, approvals and fraud-prevention records.
Communications and technical
Emails, messages, call or meeting notes, complaints, website form data, IP address, device, security and cookie information.
We obtain information from you and from people acting for or with you. We may also use public registers and official sources, identity and screening providers, property-data services, banks, advisers, agents, sellers, contractors, local authorities and other transaction participants.
Where you provide information about another person, you should be authorised to do so and should make this policy available to them where appropriate.
3. Why we use information
We may use personal information for the following purposes and lawful bases:
- Enquiries, onboarding and contracted services: contract, steps before entering a contract and legitimate interests.
- Property sourcing, deal preparation, introductions and transaction support: contract and legitimate interests.
- Identity, AML, sanctions, PEP, fraud and source-of-funds checks: legal obligation and legitimate interests, with additional legal conditions where sensitive or criminal-offence information is involved.
- Client Money, banking, invoicing and accounting: contract, legal obligation and legitimate interests.
- Complaints, disputes, debt recovery and legal claims: legal obligation, contract and legitimate interests.
- Business security, quality control and service improvement: legitimate interests.
- Marketing and non-essential cookies: consent where required, otherwise legitimate interests subject to your right to object and applicable marketing rules.
We use only the information reasonably necessary for the relevant purpose. Failure to provide information needed for a contract, AML checks, authority or funding verification may prevent us from starting or continuing a service, presenting an opportunity, receiving money or completing an instruction.
4. AML, Client Money and confidentiality restrictions
Property transactions can require customer due diligence, beneficial-ownership checks, sanctions and PEP screening, source-of-funds or source-of-wealth evidence, ongoing monitoring and fraud-prevention checks. These checks may involve information about political exposure, alleged or confirmed unlawful conduct, legal proceedings or other sensitive matters.
Where K&M has separately agreed to receive or hold Client Money, we may use payer identity, bank details, transaction purpose, ownership, funding evidence, release and refund instructions, ledger entries and payment confirmations. Unexpected or third-party payments may require additional checks, and we may verify bank details independently before making a release or refund.
5. Who we share information with
We share personal information only where reasonably necessary and lawful. Recipients may include:
- solicitors, conveyancers, estate agents, sellers, buyers, developers, lenders, brokers, surveyors, valuers, contractors, accountants, tax advisers, letting agents and other relevant transaction parties;
- identity-verification, AML, sanctions, PEP, adverse-media, fraud-prevention and property-data providers;
- banks, payment processors, insurers, auditors, legal advisers, claims handlers, redress schemes and professional bodies;
- cloud, email, document-storage, CRM, website, security, communications and IT providers acting under appropriate arrangements; and
- HMRC, the National Crime Agency, police, courts, the ICO, Companies House, local authorities and other regulators or competent authorities where required or permitted.
We do not sell personal information to advertisers or unrelated third parties. Where another organisation acts as an independent controller, it is responsible for its own use of the information.
6. International transfers
Some suppliers may store or access information outside the United Kingdom. Where a restricted international transfer occurs, we will use an appropriate lawful safeguard, such as an adequacy decision, approved contractual terms or another permitted mechanism, and assess additional protections where required.
7. How long we keep information
Retention may be extended where information is needed for litigation, a complaint, investigation, regulatory request, legal hold, fraud prevention or another continuing legal obligation. Information is deleted or anonymised when there is no longer a lawful reason to keep it.
8. Your rights
Depending on the circumstances and lawful basis, you may have rights to be informed, request access, correct inaccurate information, request erasure or restriction, object to processing, receive certain information in a portable format, withdraw consent and request human review of a qualifying solely automated decision.
These rights are not absolute. We may need to retain or withhold information to comply with AML or other law, prevent crime, protect another person, preserve legal privilege, or establish, exercise or defend legal rights.
To exercise a right, email info@knmpropertysolutions.co.uk. We may ask for evidence of identity and authority and will respond within the applicable legal timescale.
9. Security, accuracy and automated tools
We use proportionate organisational and technical measures to protect information, including access controls, authentication, secure storage, backup, supplier controls and payment-verification procedures. No system is completely risk-free, but suspected loss, misuse or unauthorised access will be investigated and handled under our incident procedures.
Please provide accurate and current information and tell us promptly when identity, contact, ownership, authority, funding, bank or transaction details change. We may request additional verification before accepting amended bank or payment instructions.
We may use structured risk assessments, screening results and scoring tools to support AML, fraud and customer-risk decisions. We do not intend to make decisions producing legal or similarly significant effects solely by automated means without the safeguards required by law.
10. Website, cookies and children
Our website may use strictly necessary cookies and similar technologies for operation, security and form functionality. If we introduce non-essential analytics, preference or advertising technologies, we will provide appropriate information and obtain consent where required. Links to third-party websites are governed by those organisations’ privacy policies.
Our services are directed primarily to adults and organisations. We do not knowingly market property sourcing or deal-packaging services to children. Information about a person under 18 may be handled where relevant to ownership, inheritance, a trust, guardianship or another lawful transaction and with appropriate safeguards.
11. Questions, complaints and changes
Questions, rights requests and data-protection complaints should be sent to the Director / Data Protection Lead at info@knmpropertysolutions.co.uk, by telephone on 07871 426607, or by post to 33–34 Winckley Square, Preston, England, PR1 3JJ.
We would appreciate the opportunity to address a concern first, but this does not affect your right to complain to the Information Commissioner’s Office.
ico.org.uk • 0303 123 1113 • Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
We may update this policy where law, guidance, services, technology, suppliers or business practices change. The current version will be available on this website or on request, and material changes may be brought directly to affected people where appropriate.
K&M Property Solutions Ltd
Company No. 17307744 • ICO Registration ZC187065
info@knmpropertysolutions.co.uk
07871 426607
33–34 Winckley Square, Preston, England, PR1 3JJ