Privacy Policy

1. Introduction

This Privacy Policy explains how Lifestyle Property People Ltd, trading as Lifestyle Property Group ("we", "us", or "our") collects, uses, shares and protects your personal data.

It applies to our website at https://lifestylepropertygroup.co.uk (the "Service"), and to all other ways we interact with you, including by telephone, email, SMS, WhatsApp, video call, social media and in person.

It also covers personal data we still hold that was originally collected through our earlier websites, including lifestylepropertypeople.co.uk, which now redirects to our current site.

Data Controller: Lifestyle Property People Ltd
Company Registration Number: 09956009 (registered in England and Wales)
Registered Office: 9 Freetrade House, Lowther Road, Stanmore, England, HA7 1EP
ICO Registration Number: ZA173272
Data Protection Contact: info@lifestylepp.co.uk

We are the data controller for the personal data described in this policy, which means we are responsible for deciding how and why it is used.

Regulatory memberships. We are registered with The Property Ombudsman (TPO), the independent redress scheme for property professionals. We are not authorised or regulated by the Financial Conduct Authority, and nothing we provide constitutes regulated financial advice.

2. Who This Policy Applies To

This policy applies to:

• Website visitors
• Prospective and existing clients and investors
• Property vendors, sellers and landlords
• Tenants and prospective tenants (where we act for a landlord client)
• Contractors, suppliers and professional partners
• People who refer others to us, and people who are referred to us
• Job applicants
• Anyone else we interact with in the course of our business

3. The Personal Data We Collect

3.1 Information you give us

• Identity and contact data: full name, email address, telephone and mobile number, postal address, WhatsApp number, date of birth
• Investment and property data: investment budget, funding position, timescales, portfolio details, property preferences, target yields, existing property ownership
• Financial data: source of funds information, mortgage or finance arrangements, proof of deposit, bank details for transactions
• Compliance data: identification documents such as passport, driving licence and proof of address, collected for anti-money laundering (AML) and know-your-client (KYC) purposes
• Correspondence: the content of your enquiries, emails, SMS messages, WhatsApp messages, web form submissions and social media messages
• Booking data: appointment times, attendance, cancellations and rescheduling
• Feedback: testimonials, review content and survey responses

3.2 Information we collect automatically

• Technical data: IP address, browser type and version, device type, operating system, time zone and screen resolution
• Usage data: pages viewed, time on page, referring source, click behaviour, scroll depth, forms started and completed
• Advertising identifiers: cookie IDs and advertising IDs used to measure and target advertising
• Session recordings: where you have consented to analytics cookies, a replay of your visit including mouse movement, clicks, taps and scrolling. Text entered into form fields is masked and these recordings are deleted after 30 days.

We collect this using cookies and similar technologies. See section 9 and our Cookie Policy.

3.3 Information we record

• Call and video meeting recordings, transcripts and AI-generated summaries. See section 6 for full detail.
• Telephone call metadata such as time, duration and outcome.

3.4 Special category data

We do not routinely collect special category data (such as health data or ethnicity). If you volunteer information about, for example, a health condition affecting a purchase timescale, we will only record it where necessary and will rely on your explicit consent or another lawful condition under Article 9 of the UK GDPR.

We do not knowingly collect data from anyone under 18. Our services are not directed at children.

4. Where We Get Your Data From

As well as data you give us directly, we may receive your personal data from:

• Referrals: existing clients, contacts or partners who pass on your details, including through our refer-a-friend scheme
• Our own advertising: lead forms you complete on Facebook or Instagram in response to our adverts, which Meta then passes to us
• Publicly available sources: HM Land Registry, Companies House, property portals and public directories, used for property research and due diligence on a transaction rather than for marketing
• Professional partners: letting agents, brokers, solicitors, accountants and introducers
• Credit reference and identity verification agencies, where we carry out compliance or affordability checks
• Our previous websites and systems. Some records date from enquiries made through our earlier websites, including lifestylepropertypeople.co.uk, before we traded as Lifestyle Property Group. Those records were held in systems previously used by the business, including Asana, Pipedrive, Street CRM and Deal Metrics, and have since been consolidated into our current CRM. If you enquired with us before that migration, this is where your record came from.

We have never bought, rented or otherwise acquired marketing lists from third parties, and we do not do so now. Every person on our database came to us directly: through our website, an enquiry form, one of our own adverts, or a referral made with permission. This includes the historical records migrated from our previous systems.

If someone refers you to us, we will tell you where we got your details from the first time we contact you, and we ask everyone who refers a contact to confirm they have that person's permission.

5. How We Use Your Data and Our Lawful Bases

Where we rely on legitimate interests, we have considered whether our interests are outweighed by the impact on you. You can ask us for a copy of that assessment at any time.

Where we rely on consent, you can withdraw it at any time. This will not affect anything we did before you withdrew it.

6. Call and Video Meeting Recording

We record most sales and consultation calls. This includes video calls held on platforms such as Zoom, Microsoft Teams and Google Meet.

How it works:

• Recording is carried out using Fathom, an AI meeting assistant. It joins the call, records audio and video, produces a written transcript and generates an AI summary of what was discussed.
• You will be told at the start of the call that it is being recorded, and the platform or the assistant will display a visible indicator.
• If you do not want to be recorded, tell us and we will turn recording off. The call will go ahead as normal.

What we use recordings for:

• Accurate records of what was discussed and agreed
• Internal handover between team members
• Training, coaching and quality assurance
• Improving our service, marketing and frequently asked questions content

Who can access recordings: authorised members of our team, and Fathom as our processor. We do not publish recordings or use them in marketing without your separate written permission.

How long we keep them: see section 13.

Telephone calls. We do not record ordinary telephone calls made or received through our CRM telephony. We do log call activity, such as the time, duration and outcome of a call, so we have a record of our contact with you.

7. Marketing: Email, SMS and WhatsApp

We use email, SMS and WhatsApp to keep in touch with prospective and existing clients. This includes automated sequences that run over an extended period, in some cases up to 12 months, and shorter reminder sequences around booked appointments.

7.1 Email

We will send you marketing email where you have consented, or where you have enquired about similar services and we have given you the chance to opt out (the "soft opt-in" under the Privacy and Electronic Communications Regulations).

7.2 SMS

We send SMS for appointment confirmations, reminders and marketing content. Reply STOP to any message to opt out of SMS. Message frequency varies. Your network's standard message rates apply.

7.3 WhatsApp

We use WhatsApp Business as a primary channel for appointment reminders, confirmations and conversational follow-up.

• We will only message you on WhatsApp where you have given us your number for that purpose and opted in.
• WhatsApp messages are delivered through WhatsApp Ireland Limited (part of Meta) and our messaging platform provider. Meta processes message data in accordance with its own terms, and message content and metadata may be processed outside the UK.
• Reply STOP at any time to stop receiving WhatsApp messages from us. You can also block our number in WhatsApp.
• WhatsApp is end-to-end encrypted in transit, but please do not send us identification documents or financial details over WhatsApp. We will always ask for those by secure email or through a secure upload.

7.4 Opting out

You can opt out at any time by:

• Clicking unsubscribe in any marketing email
• Replying STOP to any SMS or WhatsApp message
• Emailing info@lifestylepp.co.uk

You have an absolute right to object to direct marketing. We will action it without needing a reason from you.

When you opt out we add your details to a suppression list. We keep that suppression record indefinitely so we do not accidentally contact you again. That is the only reason we keep it.

8. Advertising and Social Media

We advertise on Meta (Facebook and Instagram) and may advertise on other platforms including Google and LinkedIn. This involves the following:

• Meta Pixel and Conversions API. With your consent, we place the Meta Pixel on our website. It records actions you take, such as viewing a page or submitting a form, and sends them to Meta so we can measure our advertising and show you relevant ads. We may also send this event data to Meta from our server.
• Custom Audiences. We may upload contact details, in hashed form, so Meta can match them to platform users and show or suppress ads accordingly.
• Lookalike Audiences. Meta may use those audiences to find users with similar characteristics. We do not receive the personal data of anyone in a lookalike audience.
• Lead ads. If you submit a form inside Facebook or Instagram, Meta passes those details to us.

Joint controllership. For some of this processing, particularly Custom Audiences and audience insights, we and Meta act as joint controllers. Meta's own responsibilities are set out in its terms and privacy policy at https://www.facebook.com/privacy/policy.

You can control this. Reject advertising cookies in our cookie banner, and use the ad preferences and "Why am I seeing this ad?" controls in your Meta account settings. You can also ask us to remove you from our advertising audiences by emailing us.

9. Cookies and Website Tracking

We use cookies and similar technologies for essential site function, analytics and advertising.

Non-essential cookies, including analytics and advertising cookies, are only set where you consent through our cookie banner. You can change or withdraw your choices at any time using the cookie settings link on our website.

Full detail of the cookies we use, their purpose and how long they last is in our Cookie Policy.

10. Automated Processing and AI Tools

We use software and AI tools to help us work more efficiently, including:

• AI transcription and summarisation of calls and meetings (see section 6)
• Automated workflows in our CRM that send messages, set tasks and move records between stages based on your actions, such as opening an email, booking a call or not attending an appointment
• Lead prioritisation based on the information you provide and how you engage with us

We do not make decisions that have a legal or similarly significant effect on you by automated means alone. A member of our team is always involved in decisions about whether and how we work with you. You can ask us to explain how any automated process has affected you.

11. Who We Share Your Data With

11.1 Our group and connected businesses

We may share your data with other companies in our group where that is necessary to deliver a service to you, for example arranging refurbishment works or the ongoing letting and management of a property you purchase:

Each of these is a separate legal entity and a separate data controller in its own right. Where we pass your data to another group company, that company becomes responsible for how it uses your data from that point, and will handle it in line with this policy. We only share what is necessary for the service being provided.

11.2 Service providers acting on our instructions

All of these providers are bound by contract to process your data only on our instructions and to keep it secure.

11.3 Others we may share with

• Letting and estate agents, and property management companies
• Solicitors, conveyancers, surveyors and mortgage brokers
• Contractors and trades working on a property
• Accountants and auditors
• Insurers and professional advisers
• The Property Ombudsman, where you make a complaint that is escalated to the scheme, or where TPO requests information as part of an investigation or audit
• HM Revenue and Customs, regulators and law enforcement, where we are required to disclose

11.4 Other disclosures

We may also disclose personal data:

• To comply with a legal or regulatory obligation, including AML reporting
• To establish, exercise or defend legal claims
• In connection with the sale, purchase or restructuring of our business, in which case the recipient will be bound by this policy

We do not sell your personal data.

12. International Transfers

Several of our providers are based outside the United Kingdom, mainly in the United States. This means your personal data may be transferred to and stored outside the UK.

Where that happens, we make sure at least one of the following safeguards is in place:

• The country has UK adequacy regulations, or the provider is certified under the UK Extension to the EU-US Data Privacy Framework
• The International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, supported by a transfer risk assessment

You can request more detail about the safeguards applying to a specific transfer by emailing info@lifestylepp.co.uk.

13. How Long We Keep Your Data

At the end of these periods we securely delete or anonymise the data. Where deletion is not immediately possible, for example in backups, we isolate the data and delete it on the next scheduled cycle.

14. How We Protect Your Data

We use appropriate technical and organisational measures, including:

• Access controls and role-based permissions in our systems
• Multi-factor authentication on business-critical accounts
• Encryption of data in transit
• Reputable providers with recognised security standards
• Staff and contractor training on data protection
• Written contracts with everyone who processes data on our behalf
• A process for identifying, recording and reporting personal data breaches, including reporting to the ICO within 72 hours where required

No system is completely secure. If a breach is likely to result in a high risk to your rights and freedoms, we will tell you without undue delay.

15. Your Rights

Under the UK GDPR you have the right to:

• Be informed about how we use your data, which is what this policy is for
• Access a copy of the personal data we hold about you
• Rectification of inaccurate or incomplete data
• Erasure of your data, where there is no overriding reason for us to keep it
• Restrict processing in certain circumstances
• Object to processing based on legitimate interests, and an absolute right to object to direct marketing
• Data portability, where processing is based on consent or contract and carried out by automated means
• Withdraw consent at any time
• Not be subject to solely automated decisions with legal or similarly significant effects
• Complain to the Information Commissioner's Office

To exercise any of these rights, email info@lifestylepp.co.uk.

We will respond within one month. If your request is complex we may extend this by up to two further months, and we will tell you if we need to. We will not charge a fee unless your request is manifestly unfounded or excessive. We may ask you to verify your identity first.

Please note: where we hold data to meet an AML or accounting obligation, we may not be able to delete it on request, even if you ask us to.

16. Third-Party Websites and Links

Our website and our messages may contain links to third-party websites, including property portals, review sites and social media platforms. We are not responsible for their privacy practices. Please read their policies before providing them with personal data.

17. Changes to This Policy

We may update this policy to reflect changes in our services, our systems or the law. The current version is always available on our website, and the "Last Updated" date at the top shows when it last changed.

Where a change materially affects how we use your data, we will tell you directly, for example by email, before it takes effect.

18. How to Contact Us and How to Complain

Lifestyle Property People Ltd trading as Lifestyle Property Group
Company number 09956009. ICO registration ZA173272.
9 Freetrade House, Lowther Road, Stanmore, England, HA7 1EP

Email: info@lifestylepp.co.uk

If you are unhappy with how we have handled your personal data, please contact us first so we can try to put it right.

For data protection complaints, you have the right to complain to the UK's data protection regulator:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/

For complaints about our property services, you can escalate to our independent redress scheme once you have been through our own complaints process:

The Property Ombudsman
Milford House, 43 to 55 Milford Street, Salisbury, Wiltshire, SP1 2BP
Website: https://www.tpos.co.uk