Privacy Policy | Ethics & Professionalism Policy | Anti-money Laundering and Client Due Diligence Policy | Complaints Handling Policy

Privacy Policy Oct 29, 2026 

1. Who we are and what this policy covers

This policy explains how The Viewing Real Estate Limited ("The Viewing", "we", "us") collects, uses, shares and protects personal data. We are the data controller for the personal data described here.

• Company: The Viewing Real Estate Limited, a company registered in England and Wales, company number 09926451
• ICO registration number: ZA174816
• Contact for privacy questions: gemma@the-viewing.com
• Website: www.the-viewing.com

This policy applies to:

• buyers and potential buyers who enquire with us, including through our Property Finding, Auctions and Influencer Connect services;
• people referred to us by an influencer in our Influencer Connect network;
• estate agents, influencers, partners and suppliers we work with, and their staff;
• visitors to our website and people who contact us by email, phone, WhatsApp or social media.

We comply with the UK General Data Protection Regulation and Data Protection Act 2018 and, where it applies to people in the European Economic Area, the EU General Data Protection Regulation (together, "data protection law").

2. The personal data we collect and where it comes from

From you directly, when you fill in one of our forms, message us or speak to us:

• identity and contact details: name, email address, phone or WhatsApp number, country of residence, preferred contact method;
• your property requirements: the properties you are interested in, budget range, timeframe, preferred locations and anything else you tell us about what you are looking for;
• the content of your messages and our notes of conversations, viewings and negotiations;
• your marketing preferences and a record of any consents you give us;
• where you go on to buy, information needed for the transaction and any identity or anti-money-laundering checks the law requires.

From an influencer who referred you. If you contacted an influencer in our Influencer Connect network about a property, that influencer may pass us your name, contact details, the property or post you asked about, and the influencer's own name, so we can respond to you. Where possible we ask influencers to point you to our own enquiry form, so that you give your details to us directly.

From estate agents and partners we work with on a property you are interested in, such as viewing feedback or the progress of an offer.

About estate agents, influencers and partners: business contact details, the properties or audiences you work with, commission and invoicing details, and for influencers, payment and tax-status details.

From our website and social media: technical information such as IP address and browser type, and how you use our site, as described in our cookie policy. Social media platforms (for example Meta, for Instagram, Facebook and WhatsApp) also process data about you as separate controllers under their own privacy policies.

We do not ask for special category data (such as health, religion or ethnicity). Please do not send it to us.

3. How we use your data and our legal basis

Data protection law requires a legal basis for each use of personal data. Ours are set out below.

What we do	Legal basis
Respond to your enquiry, including one passed to us by an influencer	Steps you have asked us to take before entering into a contract; our legitimate interest in responding to people who contact us
Introduce you to the estate agent(s) selling properties you are interested in, and arrange viewings, travel and translation	Your consent, given on our enquiry form or when we first contact you; steps you have asked us to take before a contract
Support you through an offer, negotiation and purchase, working with agents, notaries and lawyers	Performance of our contract with you; steps before a contract
Keep the referring influencer updated on the progress of your enquiry, and calculate commission due to them	Our legitimate interest in running our referral network and paying influencers accurately
Send you details of other properties that match your requirements	Your consent, which is optional and can be withdrawn at any time
Manage our relationships with estate agents, influencers and partners, including invoicing and payments	Performance of our contract with them; our legitimate interests
Carry out identity and anti-money-laundering checks, keep financial records and meet tax obligations	Compliance with a legal obligation
Establish, exercise or defend legal claims, including under non-circumvention terms in our agreements	Our legitimate interests
Run, secure and improve our website	Our legitimate interests; your consent for non-essential cookies

Where we rely on legitimate interests, we have weighed them against your rights and expectations. You can ask us for details of that assessment, and you can object at any time (see section 7).

Where we rely on consent, you can withdraw it at any time by contacting us. Withdrawing consent does not affect anything we did before you withdrew it.

We do not make decisions about you based solely on automated processing. We may use software, including AI tools, to help organise and route enquiries, but a person at The Viewing handles your first real conversation, the qualification of your enquiry and any negotiation.

4. Who we share your data with

We never sell your personal data. We share it only as follows.

Estate agents. With your agreement, we share your name, contact details and requirements with the estate agent(s) selling the properties you are interested in, so they can host viewings and handle the sale. Agents may be based in the UK, France, Spain, Portugal, Italy, Greece or elsewhere in Europe. Each agent becomes a separate controller of your data and will handle it under its own privacy policy.

The influencer who referred you. If an influencer in our Influencer Connect network referred you, we tell them that we have received your enquiry and give them regular updates on its progress (for example "viewing arranged" or "sale completed") so that their commission can be calculated. We do not give them your contact details beyond what they already hold, or details of your finances or negotiations.

Joint controllers for referrals. For referrals, we and the referring influencer act as joint controllers. We have an agreement with each influencer that sets out our respective responsibilities. Under it, The Viewing is your main point of contact: we provide this privacy information and handle requests to exercise your rights, whichever of us you contact. You can ask us for a summary of that arrangement.

Auction partners. If you are interested in a property sold at auction, we share relevant details with our auction partner, Venteu.

Notaries, lawyers and other professionals involved in your purchase, at your request.

Our service providers, who process data on our behalf under contract and only on our instructions, including:

• website hosting and database: Microsoft Azure (West Europe data centre, the Netherlands);
• email newsletters and mailing lists: Mailchimp;
• customer database and CRM: Airtable;
• messaging and enquiry management: respond.io, and WhatsApp Business (Meta);
• workflow automation tools that connect these systems, such as Zapier;
• email and office software;
• accountants and IT support.

Professional advisers and authorities. Our lawyers, accountants and insurers where needed; and regulators, tax authorities, law enforcement or courts where the law requires it.

A future owner. If our business is sold or restructured, data may transfer to the new owner, who will be bound by this policy.

5. International transfers, retention and security

International transfers. We are based in the UK and work with agents across Europe. The UK and the EU recognise each other's data protection standards, so transfers between them need no extra safeguards. Some of our service providers (for example Mailchimp, Airtable, respond.io and Zapier) may store or access data in the United States or other countries. Where that happens we rely on an adequacy decision (including the UK Extension to the EU–US Data Privacy Framework where the provider is certified), or on approved contractual safeguards such as the UK International Data Transfer Addendum and the EU Standard Contractual Clauses. You can ask us for a copy of the relevant safeguards.

How long we keep your data.

Data	How long we keep it
Enquiries that do not lead to a purchase	24 months from our last contact with you, then deleted
Buyer clients who complete a purchase	6 years after completion, for legal, tax and anti-money-laundering purposes, plus any period needed to deal with claims
Referral records (which influencer referred which buyer)	For the life of the influencer agreement plus 12 months, and longer if needed to settle commission or a dispute
Agent, influencer and partner records	For the life of our relationship plus 6 years
Marketing preferences	Until you unsubscribe or withdraw consent, plus a suppression record so we do not contact you again

Security. We use access controls, password protection and two-factor authentication on our systems, limit access to people who need it, and require our service providers to protect data to the same standard. If a breach is likely to put your rights at risk, we will notify the regulator and, where required, you.

6. Marketing

We only send you property updates or newsletters by email, WhatsApp or text if you have opted in, or if you are an existing client and we are telling you about similar services (you can opt out at any time). Every message tells you how to unsubscribe. Consent you gave to an influencer or another company does not count as consent to marketing from us.

7. Your rights

You have the right to:

• access a copy of the personal data we hold about you;
• correct data that is wrong or incomplete;
• erase your data where we no longer have a reason to keep it;
• restrict how we use your data while a concern is resolved;
• object to our use of your data based on legitimate interests, and to direct marketing at any time;
• data portability: receive data you gave us in a machine-readable format, or have it sent to another organisation;
• withdraw consent at any time where we rely on it.

To use any of these rights, email gemma@the-viewing.com. We will respond within one month and there is normally no charge. We may need to confirm your identity first. If you were referred by an influencer, you can contact us directly; you do not need to go through the influencer.

8. Cookies

Our website uses cookies: small files stored in your browser that help the site work and show us how it is used. When you first visit, we ask whether you agree to non-essential cookies. Strictly necessary cookies are always set, because the site cannot work without them.

Cookie	Type	Purpose
.ASPXAUTH, ASP.NET_SessionId	Our own, strictly necessary	Keep you signed in and manage your session while you use the site
ARRAffinity	Our own, optional	Directs you to the most appropriate server to manage load. No identifiable data is stored
__RequestVerificationToken	Our own, strictly necessary	Checks that forms are submitted by a real person, not a bot
_ga, _gat	Third party (Google Analytics), optional	Count visitors and show how they use the site, so we can improve it

You can change your cookie choices at any time, or block cookies in your browser settings. Blocking strictly necessary cookies may stop parts of the site working. More information is available at www.allaboutcookies.org.

Our site may link to other websites, such as those of agents and partners. They have their own privacy policies, which we are not responsible for.

9. Children

Our services are for adults. We do not knowingly collect data from anyone under 18.

10. Complaints

Please contact us first so we can try to resolve your concern. You also have the right to complain to a data protection regulator:

• in the UK, the Information Commissioner's Office: ico.org.uk, 0303 123 1113;
• in the EU, the supervisory authority in the country where you live or work, or where you think the problem happened.

11. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.

Last updated: 29 October 2026

12. Contact us

The Viewing Real Estate Limited, company number 09926451

Email: gemma@the-viewing.com

Privacy Policy updated 29.10.26

 

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.

Next scheduled review: July 2027

 

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 2026