Privacy Policy

Who we are

Hurlingham Property Management is a company registered in England and Wales (company number11143510 with its registered office at 66 Paul Street, London EC2A 4NE. We are the "data controller" of the personal information described in this notice.

We are registered with the Information Commissioner's Office (ICO)

Contact for privacy matters: clientservices@hurlinghamadvisory.com · 66 Paul Street, London EC2A 4NE · +44 (0) 20 8798 0166

The information we collect

Prospective clients and website enquiries: name, email address, phone number (if provided), portfolio details you share with us (number of units, location, situation), and the content of your messages.

Clients (property owners): identity and contact details, bank account details for rent remittance, property and tenancy records, ownership and title information, anti-money-laundering verification documents where required, and correspondence.

Tenants and occupiers of managed properties: identity and contact details, referencing information (including credit checks carried out by third-party referencing providers), right-to-rent documentation, tenancy records, payment history, and maintenance correspondence.

Contractors and suppliers: contact details, insurance and qualification documents, and payment details.

Website visitors: technical data (IP address, browser type, device information) and usage data collected via cookies and similar technologies — see section 8.

How we use it and our lawful bases

We use personal information only where UK GDPR gives us a lawful basis to do so. When you make an enquiry or request a portfolio review, we process your details on the basis of our legitimate interests and as steps taken prior to entering a contract. Once you become a client, most of our processing — managing your properties, collecting rent, operating client accounting and remitting funds, and providing owner reporting — is carried out because it is necessary for the performance of our management agreement with you.

Some processing is required of us by law. Tenant referencing, right-to-rent checks and deposit protection are carried out under a combination of legal obligation and the performance of tenancy arrangements; anti-money-laundering and sanctions checks, and our compliance with housing, licensing and health-and-safety law, are legal obligations in their own right.

Where we contact business clients and contacts about our services, we rely on our legitimate interests, and you may opt out of such communications at any time. Website analytics and security processing is likewise based on our legitimate interests, except that non-essential cookies are used only with your consent, which you may withdraw at any time through the cookie settings.

We do not sell personal information.

Who we share it with

Where necessary for the purposes above: tenant referencing and credit-check providers; deposit protection schemes; contractors attending managed properties (name and access details only, as required); our banking, accounting, IT and CRM providers; professional advisers (legal, accounting, insurance); our client money protection scheme and redress scheme in connection with any claim or complaint; regulators, HMRC and law-enforcement bodies where required by law; and other companies within the Hurlingham Advisory group for administration of our services.

Where we use service providers who process data on our behalf, they act under written data-processing terms.

International transfers

Some of the service providers who process personal data on our behalf are located, or host data, outside the United Kingdom. Our website is built and hosted on the Wix platform (Wix.com Ltd, headquartered in Israel, with hosting infrastructure in various locations); our domains and email routing are provided through one.com (operated from within the European Economic Area); our business email and document systems are provided by Google Workspace (Google's infrastructure includes locations in the United States); our client-relationship records are held in Qobrix (operated from within the EEA); and our property and tenancy management records are held in Bidrento (operated from within the EEA).

Where personal data is transferred to, or accessible from, a country outside the UK, we rely on one of the safeguards recognised by UK law: UK adequacy regulations (which cover the European Economic Area and, for most purposes, Israel), the UK Extension to the EU–US Data Privacy Framework in respect of certified US providers, or the UK International Data Transfer Agreement or Addendum incorporated into the provider's data-processing terms. Each of these providers processes personal data under written data-processing terms with us.

How long we keep it

Enquiries that do not become clients: up to [24] months from last contact.
Client and tenancy records: for the duration of the relationship and generally [6] years afterwards, reflecting limitation periods and tax obligations.
Anti-money-laundering records: [5] years from the end of the relationship, as required by law.
We keep some records longer where the law requires or a dispute is ongoing.

Your rights

Under UK data protection law you have the right to: access your personal data; have inaccurate data corrected; have data erased in certain circumstances; restrict or object to processing (including direct marketing, where objection is absolute); data portability in certain circumstances; and to withdraw consent where processing is based on consent.

To exercise any right, contactclientservices@hurlinghamadvisory.com. We respond within one month. You also have the right to complain to the ICO (ico.org.uk · 0303 123 1113), though we would welcome the chance to resolve any concern first.

Cookies

Here's the section rewritten to reflect the actual build — Wix platform, its cookie set, and the booking embed that's coming:

This website is built on the Wix platform, which sets a small number of essential cookies that are required for the site to function — these support security (such as protection against cross-site request forgery), load-balancing, and the correct display of pages during your visit, and they cannot be switched off. With your consent, we also use analytics cookies, provided through Wix's visitor-analytics tools, which help us understand in aggregate how the site is used — for example, which pages are visited and for how long. These do not identify you personally to us.

Where our site includes embedded tools from third parties — such as the appointment-booking calendar used to schedule portfolio reviews — those providers may set their own cookies when you interact with the embedded element, and their use of cookies is governed by their own policies.

When you first visit the site, a cookie banner allows you to accept or decline non-essential cookies, and you can change your choice at any time through the cookie settings on this site or through your browser settings. Declining non-essential cookies does not affect your ability to use the website. A full list of the cookies currently set by this site is available through the cookie settings panel.

Security

We apply appropriate technical and organisational measures, including access controls, encrypted transmission, and staff confidentiality obligations. No internet transmission is completely secure; transmission is at your own risk.

Changes

We may update this notice from time to time. The current version will always be available on this page with its date.