Policies

 

PRIVACY AND COOKIES POLICY

1 Introduction

1.1 The Viewing Real Estate Limited (“We”) are committed to protecting and respecting your privacy.

1.2 We set out here the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it. We confirm that we have updated our procedures in line with the General Data Protection Regulation (GDPR) which takes effect across the European Union from 25th May 2018.

1.3 Who we are. Any information provided to or gathered from our site in the course of providing services to you is controlled by The Viewing Real Estate Limited, a limited liability company incorporated under the laws of England and Wales and our registered office is at 3rd Floor, 86-90 Paul Street, London EC2A 4NE. We are registered as a data controller with the Information Commissioner’s Office and our registration number is ZA174816.

2 Information we may collect from you

2.1 We may collect and process the following data about you:

(a) Information you give us. You may give us information about you by filling in forms on our site www.the-viewing.com (our “Site”) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, subscribe to our service, place an order on our Site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey and when you report a problem with our Site. The information you give us may include your name, address, e-mail address, postal address (should you request hard copy brochures to be delivered to you) and telephone number.

(b) Information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:

(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and version, operating system and platform;

(ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clocks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

(c) Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties, (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. We have confirmation from the third parties we work closely with that they meet the required standards for GDPR.

3 Cookies

3.1 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. When you visit our Site, we will ask you whether you agree to our use of cookies. If you do not agree, then you may continue to use our site but your browsing experience may be adversely affected.

3.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

3.3 We use the following cookies:

(a) Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.

(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

(c) Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

3.4 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name	Cookie Type	Purpose
_.ASPAUTH ASP.NET_SessionId	Own	These cookies allow us to recognise you when you return to our Site. They are strictly necessary for you to log in, manage your account, list properties and view your statistics. If you register with us, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.
ARRAffinity	Own	These cookies allow us to manage load on our servers by directing users to the most appropriate server for their session. No identifiable data is stored. These cookies are optional.
_RequestVerificationToken	Own	These cookies are used to ensure that when you submit data to us that it is done on behalf of a real user, not a bot or other computer script.
_ga _gat	Third Party – Google Analytics	These analytical/performance cookies allow us to use Google Analytics to analyse visitor numbers and behaviour. These cookies are optional.

 

3.5 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

3.6 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site. More information on how to set your browser’s parameters in relation to cookies can be found on the third party, independent, external resource www.allaboutcookies.org

4 Uses made of the information

4.1 We use the information held about you in the following ways:

(a) Information you give to us. We will use this information:

(i) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

(ii) to facilitate the process of bringing users of the website into contact with each other;

(iii) to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;

(iv) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this by ticking the relevant box. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please do not tick the relevant box situated on the form on which we collect your data;

(v) to notify you about changes to our service; and

(vi) to ensure that content from our Site is presented in the most effective manner for you and for your computer.

(b) Information we collect about you. We will use this information:

(i) to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(ii) to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;

(iii) to allow you to participate in interactive features of our service, when you choose to do so;

(iv) as part of our efforts to keep our Site safe and secure;

(v) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

(vi) to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.

5 Disclosure of your information

5.1 We may share your information with selected third parties including:

(a) Business partners, suppliers and sub-contractors for the sole performance of any contract we enter into with you.

(b) Analytics and search engine providers that assist us in the improvement and optimisation of our Site.

(c) Agents that we engage to perform functions on our behalf including fulfilling order deliveries, sending customer communications, analysing data, providing marketing assistance, processing payments and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

When we share your information with selected third parties they will process your information as either a data controller or as our data processor and this will depend on the purpose of our sharing your personal data. We will only share your personal data in compliance with the applicable data protection legislation. A list of our selected third parties with whom we may share your information is available by contacting us at help@the-viewing.com.

5.2 We may disclose your personal information to third parties:

(a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

(b) If The Viewing Real Estate Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

(c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of The Viewing Real Estate Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

6 Where we store your personal data

6.1 All information you provide to us is stored securely with all our computers and database access password protected. Our databases are held on our secure servers in Microsoft Azure’s West Europe (Netherlands) data centre and held on Mailchimp in the U.S.A.

6.2 We may transfer your personal information to other countries and make it accessible to the third parties identified above. We will take all steps required by GDPR 2018 legislation to ensure that your data is treated securely and in accordance with this privacy policy.

6.3 At present no payments transactions are processed through our website but should we provide this facility in the future any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7 Your rights

7.1 Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at help@the-viewing.com and we will be glad to share with you our formal procedures and action your request accordingly.

7.2 Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8 Access to information

8.1 European Data Protection legislation gives you the right to access information held about you. Your rights to access, rectify such information, object or cancel the information we hold about you can be exercised at any time by contacting us at help@the-viewing.com and we will be glad to share with you our formal procedures for collating, exporting and deleting your data and process your request.

9 Changes to our privacy policy

9.1 Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

10 Contact

10.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at help@the-viewing.com.

Privacy Policy updated 24.05.25

 

ANTI MONEY LAUNDERING AND CLIENT DUE DILIGENCE POLICY

1. Policy Statement

The Viewing Real Estate Limited is committed to conducting business in compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations. As a regulated firm under the RICS Rules of Conduct and the UK AML Regulations, we have robust systems and controls in place to prevent our services from being used to facilitate financial crime.

2. Scope

This policy applies to:

• All employees, consultants, and directors
• All clients and transactions involving property sales, lettings, and advisory services
• All branches, both within the UK and overseas (where applicable)

3. Responsibilities

Money Laundering Reporting Officer (MLRO): Gemma Bruce, Managing Director

 Responsible for oversight of AML compliance, reporting suspicious activity, and training staff.

4. Customer Due Diligence (CDD)

We apply risk-based due diligence measures to verify the identity of all clients, including:

Individuals: Passport or photo ID, proof of address

Companies: Company registration documents, beneficial ownership details

High-Risk Clients:Enhanced Due Diligence (EDD) for politically exposed persons (PEPs), overseas entities, or cash buyers

CDD is performed:

• Before establishing a business relationship
• When there is doubt about previously obtained information
• If there are suspicions of money laundering

5. Enhanced Due Diligence (EDD)

EDD is applied where there is a higher risk of money laundering, including:

• Clients from high-risk third countries
• Complex or unusually large transactions
• Use of intermediaries or offshore entities

6. Record Keeping

We retain all relevant documentation for at least 5 years from the end of the business relationship or the completion of a transaction, including:

• Client identity and verification data
• Property transaction files
• Records of risk assessments and reports made

7. Suspicious Activity Reporting (SAR)

If any employee suspects that a client or transaction may be related to money laundering or terrorist financing:

• A Suspicious Activity Report (SAR) must be made to the MLRO
• The MLRO will assess and, if necessary, submit a report to the National Crime Agency (NCA)

No action must be taken that could amount to tipping off the client.

8. Training

All staff are required to undergo regular AML training, including:

• Recognising suspicious activity
• Understanding reporting procedures
• Updates on legislation and regulatory changes

9. Internal Controls and Monitoring

• Periodic risk assessments of clients and business areas
• Regular audits of AML procedures
• Ongoing monitoring of transactions and business relationships

Compliance with RICS and Legal Obligations

We operate in accordance with:

• RICS Professional Statement: Countering bribery and corruption, money laundering and terrorist financing
• The Money Laundering Regulations 2017
• The Proceeds of Crime Act 2002
• UK Sanctions Regime

11. Review

This policy is reviewed annually or upon significant regulatory change.

Last reviewed: July 2025

Next scheduled review: July 2026

 

ETHICS AND PROFESSIONALISM POLICY

1. Purpose

This policy outlines the ethical principles and professional standards that guide all activities undertaken by The Viewing Real Estate Limited. It ensures our employees, agents, and representatives maintain the highest levels of integrity, professionalism, and accountability when dealing with clients, partners, suppliers, and the public.

2. Scope

This policy applies to:

• All employees, consultants, and agents of The Viewing Real Estate Limited
• Any person representing the company in a professional capacity
• All business activities

3. RICS Ethical Principles

We are committed to upholding the five global ethical standards established by Royal Institute of Chartered Surveyors:

1. Act with Integrity

• Be honest and straightforward in all professional and business relationships
• Avoid conflicts of interest and disclose them where they arise
• Never mislead clients or the public

2. Always Provide a High Standard of Service

• Be diligent, professional, and informed
• Deliver work that is timely, thorough, and aligned with client objectives
• Seek continuous improvement and relevant professional development

3. Act in a Way That Promotes Trust in the Profession

• Uphold the reputation of the firm and the wider real estate profession
• Avoid conduct that discredits the industry or undermines confidence
• Act as ambassadors of ethical real estate practice

4. Treat Others with Respect

• Foster an inclusive, respectful workplace and client environment
• Avoid discrimination, bullying, or harassment in any form
• Respect cultural sensitivities, privacy, and individual dignity

5. Take Responsibility

• Be accountable for your decisions and actions
• Report wrongdoing, misconduct, or unethical behaviour promptly
• Support others in doing the right thing

4. Client Relations

We are committed to:

• Acting in our clients’ best interests with loyalty and discretion
• Providing clear, truthful marketing and advice
• Charging transparent and reasonable fees, with no hidden costs
• Ensuring strict confidentiality of client data and transactions

5. Confidentiality & Data Protection

We respect and protect the confidentiality of all client and business information in accordance with:

• RICS confidentiality principles
• UK GDPR and Data Protection Act 2018
• Internal policies on secure communication and data handling

6. Conflict of Interest

We avoid and manage conflicts of interest by:

• Disclosing any actual or potential conflict at the earliest opportunity
• Refusing instructions where independence or objectivity is compromised
• Keeping proper records of conflict management procedures

7. Anti-Bribery & Corruption

We have zero tolerance for bribery or corruption. All representatives must:

• Comply with the UK Bribery Act 2010
• Refuse gifts, hospitality, or payments that could influence decisions
• Report any suspicions of improper conduct immediately

8. Professional Development

We require all staff to:

• Maintain and develop their professional knowledge and competence
• Participate in annual **CPD (Continuing Professional Development)** activities
• Stay informed about changes in real estate law, ethics, and RICS regulations

9. Reporting Concerns (“Whistleblowing”)

All personnel are encouraged to report unethical or unlawful conduct through our confidential whistleblowing process, without fear of retaliation. All concerns will be investigated fairly and discreetly.

10. Disciplinary Action

Any breach of this policy may result in disciplinary action, including:

• Verbal or written warnings
• Termination of employment or contract

11. Review & Communication

This policy is:

• Reviewed annually by the directors
• Communicated during induction and revisited as part of ongoing training
• Aligned with the latest RICS Rules of Conduct and Professional Statements

Last reviewed: August 2025

 

CONFLICTS OF INTEREST POLICY

1. Purpose of this Policy

This policy sets out how our firm identifies, manages, and resolves actual or potential conflicts of interest in accordance with:

The RICS Rules of Conduct and Professional Statement on Conflicts of Interest, and

Our own commitment to transparency, integrity, and exceptional client service.

2. Our Commitment

As a luxury property consultancy regulated by RICS, we are required to:

• Act with integrity
• Provide a high standard of service
• Avoid conflicts of interest wherever possible, and
• Where unavoidable, manage them openly, fairly, and with informed client consent.

We place the confidentiality, trust, and best interests of our clients at the heart of our work.

3. What is a Conflict of Interest?

A conflict of interest arises when:

• We owe duties to two or more clients whose interests may conflict,
• Our own personal or commercial interests could interfere with our duties to a client, or
• We hold confidential information for one client that would be relevant to another.

Conflicts can be actual, potential, or perceived, and we treat all three with equal seriousness.

4. Identifying Conflicts

We assess conflicts at three stages:

Stage 1. Before accepting instructions – every new instruction is checked against our client database.

Stage 2 During an instruction – if circumstances change, we review any emerging risks.

Stage 3 Firmwide awareness – our staff are trained to raise potential conflicts immediately.

5. Managing Conflicts

Where a conflict is identified or suspected, we will:

1. Decline the instruction if the conflict cannot be managed fairly and transparently.

2. If management is possible, we will:

• Fully disclose the nature of the conflict to all affected clients in writing,
• Seek informed written consent before proceeding,
• Establish robust information barriers (“Chinese walls”) to protect client confidentiality, and
• Appoint separate teams or individuals to handle the instructions.

We will never accept instructions if:

• The conflict is fundamental and unmanageable,
• A client refuses consent, or
• Our independence or objectivity could reasonably be questioned.

6. Confidentiality and Information Handling

• All client information is treated as strictly confidential.
• We will not disclose or use information for any purpose other than delivering the agreed services.
• Where separate teams act for different clients, we ensure physical, digital, and procedural barriers to prevent information exchange.

7. Training and Responsibility

• All staff receive regular training on identifying and handling conflicts of interest.
• A Compliance Officer is responsible for maintaining conflict checks and ensuring adherence to RICS requirements.

8. Client Assurance

Clients are welcome to request details of our conflict checks and procedures at any time. Our firm maintains full records of conflict assessments for audit by RICS.

9. Policy Review

This policy is reviewed annually or sooner if:

• RICS issues new guidance, or
• Our business activities change in a way that could affect conflict risk.

 

COMPLAINTS HANDLING POLICY

1. Purpose and Commitment

At The Viewing Real Estate Limited we are committed to delivering the highest standards of service to our clients. We recognise the importance of transparency, accountability, and fairness when handling any concerns or complaints.

This policy sets out how we will handle complaints in a prompt, fair, and professional manner in accordance with the RICS Rules of Conduct.

2. Definition of a Complaint

A complaint is defined as:

“An expression of dissatisfaction, whether oral or written, about the service, actions, or lack of action by The Viewing Real Estate Limited, its employees, or agents, affecting a client, customer, or other stakeholder."

Complaints may include issues related to:

* Professional conduct or ethics

* Service delivery or communication

* Fees, contracts, or timelines

* Staff behaviour

* Breaches of RICS standards

3. How to Make a Complaint

Complaints can be submitted in any of the following ways:

By email:

 Gemma@the-viewing.com

By phone:

 +44 (0) 7900 247 988

  (Please note: we may request a written summary to proceed formally.)

To help us investigate your complaint promptly, please include:

* Your full name and contact details

* Property address or service in question

* A clear description of your complaint

* Copies of any relevant correspondence or documents

* Your desired resolution or outcome (if any)

4. Internal Complaints Procedure

Upon receiving your complaint:

1. Acknowledgement

   We will acknowledge your complaint within 3 working days of receipt.

2. Investigation

   The complaint will be investigated by a director not directly involved in the matter.

3. Response

   A full written response will be issued within 15 working days. If further time is needed (e.g., due to complexity), we will notify you with a revised timeline and expected resolution date.

4. Resolution

   We aim to resolve all complaints within 28 working days from the date of receipt.

5. If You Are Not Satisfied – Escalation to Independent Redress

If you remain dissatisfied after our final response or if 8 weeks have passed without resolution, you may refer your complaint to our approved redress scheme.

Residential Clients (Sales, Lettings, Property Management):

The Property Ombudsman (TPO)

Website: https://www.tpos.co.uk

Email: admin@tpos.co.uk

Phone: 01722 333306

Address: Milford House, 43–55 Milford Street, Salisbury, SP1 2BP

6. Confidentiality

All complaints will be handled sensitively and in accordance with the UK GDPR and our Privacy Policy. We will keep all details confidential and only share information when strictly necessary for investigation or legal compliance.

7. Continuous Improvement

All complaints are reviewed as part of our quality control process. Trends or recurring issues are escalated to senior management to improve training, procedures, and client experience.

8. Contact Us

If you have any questions about this policy, please contact:

gemma@the-viewing.com

This policy is reviewed annually and updated to reflect regulatory changes and business practices. Last updated: August 2025