Proper Investment Privacy Notice

Introduction

Thank you for reading our privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Important information and who we are
1. Purpose of this privacy notice
  
  This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide to us directly via our website, platform or otherwise. It is important that you read this privacy notice together with any other privacy notice, fair processing notice or privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
2. Controller
  
  Proper Investment is a property investment platform which offers investors the opportunity to buy shares in UK property owning companies.
  
  We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection manager using the details set out below.
3. Contact details
  
  Full name of legal entity: Proper Investment In Great Britain Limited
  
  Name or title of Data Protection Manager: Data Protection Manager
  
  Email address:dpm@proper-investment.co.uk
4. Changes to the privacy notice and your duty to inform us of changes
  
  We review our use of your personal data regularly. In doing so, we can change what personal data we collect, how we keep it and what we do with it. As a result, we may change this notice from time to time to keep it relevant and up to date.
  
  Any changes will be immediately posted on our websites and we recommend that you check this page regularly to keep up to date. This version was last updated on 31st May 2024 and historic versions can be obtained by contacting us.
  
  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. Third party links
  
  Our website and platform may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website or platform, we encourage you to read the privacy notice of every third party website you visit.
The data we collect about you
1. Personal data
  
  Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
  
  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  - Identity Data includes first name, maiden name, last name, username or similar identifier, National Insurance number, title, gender, date of birth and residency. We may also collect identification documents and information (such as your passport or driving licence) or image either a photo or video (where required as part of our anti-money laundering checks)..
  - Contact Data includes current address, previous address (where required), email address and telephone numbers.
  - Financial Data includes bank details, information about your work or profession, your financial position and history, which may include source of funds, source of wealth, bankruptcy or insolvency filings.
  - Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  - Technical Data includes cookies, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and platform.
  - Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  - Usage Data includes full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and other similar information about how you use our website, platform and services.
  - Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
  
  We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We may however, collect Special Categories of Personal Data such as information about your health, including any medical condition to allow us to help vulnerable customers. We will only collect the minimum amount of information required.
  
  Where permitted by law we may process information about criminal convictions, criminal offences, related security details, alleged offences including unproven allegations, spent or previous convictions, or other details provided in relation to a criminal reference check or similar.
2. If you fail to provide personal data
  
  Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?

We use different methods to collect data from and about you including through:
1. Direct interactions.
  
  You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  - avail of our services;
  - create an account on our website or platform;
  - update your information (such as when you change your address)
  - subscribe to our service or publications;
  - request marketing to be sent to you;
  - enter a promotion or survey;
  - give us some feedback.
2. Automated technologies or interactions.
  
  As you interact with our website and platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We will ask you to consent to our use of cookies when you first visit our website. You can reset your cookie preferences as part of ourCookie Policy
3. Third parties or publicly available sources.
  
  We may receive personal data about you from various third parties and public sources.
  1. Technical Data from the following parties:
    - analytics providers;
    - advertising networks;
    - search information providers.
  2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  3. Identity and Contact Data from data brokers or aggregators.
  4. Identity, Contact and Financial Data from publicly available sources such as Companies House, the Electoral Register and HM Land Registry.
  5. Identity, Contact and Financial Data from AML / anti-fraud and Credit Reference Agencies.
  6. Identity, Contact, Financial, Transaction Data from people acting on your behalf. This could be from your solicitor, a broker, as part of a joint application on an account (e.g. joint, partnership or corporate applications) or anyone nominated to act on your behalf, including a Power of Attorney. If someone acting on your behalf provides this information, we will record what’s been provided and who gave it to us.
  7. In the event that you are providing information about another individual, you must make sure that you have their permission before you share their data with us or make decisions on their behalf about how we use their data, including credit checks. Please make them aware of this privacy notice.
  8. Sometimes we may use other data in addition to this, for example we may use data that you have made public such as when you reference or interact with us via social media.
How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailingcontact@proper-investment.co.uk.
Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by emailingcontact@proper-investment.co.ukif you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer (investor or borrower), introducer or broker. This may include carrying out checks with fraud prevention, credit and tracing agencies.	Identity Contact Financial	Performance of a contract with you Necessary to comply with a legal or regulatory obligations (prevention and detection of crime, to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption) It is in our legitimate interest to manage our risk and determine what products and services we can offer and the terms of those products and services.
To process your orders or requests and to deliver services to you including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary to comply with a legal or regulatory obligation (prevention and detection of crime, to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption Necessary for our legitimate interests (to manage our risk, determine what products and services we can offer and the terms of those products and services and recover debts due to us) Necessary to comply with a legal or regulatory obligation ( to help identify you and meet our anti-money laundering obligations)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review, take a survey or provide other feedback	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal or regulatory obligation Necessary for our legitimate interests (to keep our records updated and to study how you use our products/services)
To manage any relationship with intermediaries including a record of introductions, payments made and other relevant information appropriate to managing the relationship	Identity Contact Transaction	Necessary to comply with a legal or regulatory obligation (prevention and detection of crime, to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption) Necessary for our legitimate interests (for running our business)
To manage business relationships with our professional advisers, contractors and third party providers	Identity Contact	Necessary for our legitimate interests (for running our business)
To enable you to complete a survey or to provide other feedback	Identity Contact Profile Usage Marketing and Communications	Necessary for our legitimate interests (to study how you use our products/services, to develop them and grow our business)
To administer and protect our business, our website and our platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To use data analytics to improve our website, platform, services, marketing, broker and customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of broker and customers for our services, to keep our website and platform updated and relevant, to develop our business and to inform our marketing strategy)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how you use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our services and grow our business)
Share information with any recruitment agency or search provider about your job application	Identity Contact	Necessary for our legitimate interests (for running our business)
To consider any application for a job, including CVs, and whether to progress it	Identity Contact	Necessary for our legitimate interests (for running our business)

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via the Support section of our website.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.