Effective date: 31 August 2026
This Privacy & Cookie Policy explains how UK Realty Holdings Ltd, its subsidiaries and the associated business described below collect, use, share and protect personal information, and the rights and choices available to you.
It applies when you:
This Policy is hosted at www.ukrealty.co.uk/privacy and is intended to provide one consistent privacy framework across the relevant websites, systems and services.
UK Realty Holdings Ltd is the holding company of PCL Properties Ltd and FG Property Partners Ltd. In this Policy, those three companies are referred to together as the “Group”. Oastcrown Properties Limited is not owned by UK Realty Holdings Ltd or 2911 Holdings Limited. It is an associated business under common ultimate beneficial ownership and participates by arrangement in certain shared operational systems, including the central CRM.
The company responsible for your personal information will depend on the service you receive and how and why your information is being used.
Company: Oastcrown Properties Limited (01647019)
Services/Brand: Residential sales under Kay & Co and Marler & Marler. Associated business under common ultimate beneficial ownership; not owned by UK Realty Holdings Ltd or 2911 Holdings Limited.
Company: PCL Properties Ltd (16983491)
Services/Brand: Lettings and property management under Kay & Co, Marler & Marler and UK Forbes Global Properties. Subsidiary of UK Realty Holdings Ltd.
Company: FG Property Partners Ltd (16968693)
Services/Brand: Residential sales, property search, property advisory and related services under UK Forbes Global Properties. Subsidiary of UK Realty Holdings Ltd.
Company:UK Realty Holdings Ltd (16957663)
Services/Brand: Holding company of PCL Properties Ltd and FG Property Partners Ltd; exclusive UK member of Forbes Global Properties; provider of shared Group administration, technology and data infrastructure, including administration of the central CRM. It may act as a controller or joint controller depending on the activity concerned.
Registered office for each company: Aston House, Cornwall Avenue, London N3 1LF.
In this Policy, “we”, “us” and “our” mean the relevant company or companies responsible for the processing described. Where we refer to the “Group”, we mean UK Realty Holdings Ltd, PCL Properties Ltd and FG Property Partners Ltd. Oastcrown Properties Limited is not part of the Group but is covered by this Policy because of its shared systems, data arrangements and use of the Kay & Co and Marler & Marler brands.
Where one company determines the purposes and means of processing, it will be the controller of that information. Where two or more companies jointly determine how and why particular information is used, they may act as joint controllers.
The fact that information is stored in or accessible through a shared system does not by itself mean that every participating company is a controller of that information.
Business titles: Within our businesses, certain individuals may use titles including Partner or Director as descriptions of seniority, experience or responsibility. Unless expressly stated otherwise, use of these titles does not mean that the individual is a partner in a legal partnership, a statutory director of a company or otherwise an officer of the relevant company.
Contacting us about your information: Our central contact for data protection matters is:
Data Protection Contact
UK Realty Holdings Ltd
Aston House
Cornwall Avenue
London N3 1LF
dataprotection@ukrealty.co.uk
This address may be used for privacy matters relating to any of the companies or brands covered by this Policy.
The information we collect depends upon your relationship with us and may include:
Contact and identity information
Property information
Transaction and client information
Financial and compliance information
Communications
Website and technology information
Marketing information
Certain information receives additional protection under data protection law. We do not generally require this information to provide estate agency services, but it may occasionally be relevant. For example, we may receive information about health or accessibility requirements. Compliance processes may also result in our processing information subject to additional legal protections.
Where we process special-category or criminal-offence information, we will only do so where an appropriate additional legal condition and safeguards apply. Please do not provide sensitive information unless it is relevant and necessary for the service concerned.
We may collect information directly from you or receive it from:
We may also receive your information where another person refers you to us because they believe a property or service may be relevant to you.
We only process personal information where we have a lawful basis.
What we use information for: Providing property services
Examples: Valuations, viewings, property searches, sales, lettings, property management and advisory work
Typical lawful basis: Taking steps before entering into a contract, performing a contract and/or legitimate interests
What we use information for: Managing property transactions
Examples: Offers, negotiations, sales progression, tenancy administration and communication between relevant parties
Typical lawful basis: Contract, legitimate interests and legal obligations
What we use information for: Compliance
Examples: AML, identity verification, sanctions screening, right-to-rent and regulatory requirements
Typical lawful basis: Legal obligation and other bases permitted by law
What we use information for: Client and relationship management
Examples: Maintaining records, managing contacts and recording property requirements
Typical lawful basis: Contract and legitimate interests
What we use information for: Operating shared CRM and systems
Examples: Maintaining appropriate records across participating businesses and supporting continuity, referrals and compliance
Typical lawful basis: Legitimate interests and, where applicable, contractual arrangements between controllers/processors
What we use information for: Telephone recording and monitoring
Examples: Training, quality monitoring and improving service standards
Typical lawful basis: Legitimate interests
What we use information for: AI-assisted services
Examples: Voice AI, WhatsApp AI, transcription, summarisation, enquiry handling, administration and property marketing support
Typical lawful basis: Contract, steps before contract and/or legitimate interests
What we use information for: Referrals and introductions
Examples: Introducing clients or properties to another agent, adviser or Forbes Global Properties network member
Typical lawful basis: Contract, steps before contract and/or legitimate interests
What we use information for: Security and fraud prevention
Examples: Protecting our people, customers, systems and businesses
Typical lawful basis: Legal obligation and legitimate interests
What we use information for: Complaints and legal matters
Examples: Investigating complaints and establishing, exercising or defending legal claims
Typical lawful basis: Legal obligation and legitimate interests
What we use information for: Marketing
Examples: Property alerts, market information, events, news and relevant services
Typical lawful basis: Consent and/or legitimate interests where applicable, subject to electronic marketing rules
What we use information for: Website analytics and marketing technologies
Examples: Understanding site use and measuring campaigns
Typical lawful basis: Consent where required
Where we rely on legitimate interests, we consider our interests, the necessity of the processing and its potential effect on you.
We use artificial intelligence and AI-enabled technology in parts of our customer service, communications, marketing and business operations.
Nesti voice and WhatsApp AI
We use Nesti.io Ltd (“Nesti”), a company registered in England and Wales, to provide AI-enabled voice and WhatsApp services.
Depending upon the interaction, Nesti may:
Knowing when you are dealing with AI
Where you interact directly with an AI voice or messaging assistant, we aim to identify this clearly at or near the beginning of the interaction. You may ask to communicate with a member of our team instead where appropriate.
Human involvement
AI is used to assist our communications, enquiry handling, administration and marketing. We do not use our AI assistants to make final decisions about individuals that produce legal or similarly significant effects without meaningful human involvement. Members of our team remain responsible for material decisions concerning clients, property transactions and the professional services we provide.
AI-assisted property particulars and marketing
We may use artificial intelligence to assist members of our team with drafting property descriptions, preparing property particulars, summarising property information, preparing marketing copy, creating reports and other administrative or marketing tasks.
AI-generated or AI-assisted property content is intended to support, rather than replace, professional human judgement. Property particulars and marketing content prepared with AI assistance are subject to human review before publication. AI does not change our responsibility to ensure that information provided to consumers is accurate, clear and not misleading.
AI virtual staging
We may sometimes use AI or other digital technology to virtually stage property photographs. Virtual staging may be used, for example, to illustrate how an empty or sparsely furnished room might appear when furnished or decorated.
Where AI or digital virtual staging has been used, this will be clearly stated in the relevant property description. Virtually staged images are illustrative only and may show furniture, furnishings, artwork, lighting, decoration or other non-permanent items that are not physically present at the property.
Virtual staging must not be relied upon as evidence that depicted furniture, furnishings or decorative items are included in a sale or tenancy. We do not intend to use virtual staging to conceal or materially alter structural features, condition, defects, views, room dimensions, layout or other material characteristics of a property.
AI accuracy and providers
AI technology can occasionally misunderstand information or produce inaccurate output. Information that is material to a property transaction or decision should be confirmed with the relevant member of our team and, where appropriate, an independent professional adviser.
Where third-party AI providers process personal information on our behalf, we require appropriate contractual, confidentiality, security and data-protection arrangements. Where personal information is transferred outside the United Kingdom, the international-transfer provisions in this Policy apply.
We record telephone calls for training and monitoring purposes.
Calls handled by our Nesti AI voice service may also be transcribed, summarised, written up, analysed for quality and administration, and connected with our CRM or other business systems.
Recording and monitoring enables us to train and support our teams, monitor service standards, identify problems, improve our processes, maintain appropriate records and investigate complaints or disputes where necessary.
We will provide an appropriate notification that recording is taking place. Access to recordings and transcripts is restricted according to business need.
Raw call recordings are retained only for as long as reasonably necessary for the purposes for which they were recorded. Information legitimately derived from a call and added to a client, compliance, property or transaction record may be retained for longer under our normal retention policy. A recording may also be retained for longer where reasonably necessary in connection with a complaint, investigation, dispute or legal claim.
We communicate with clients and contacts through services including WhatsApp. Where you contact us through WhatsApp, or ask us to communicate with you through it, we may use that service to answer enquiries, discuss properties, arrange appointments or viewings, provide updates, gather relevant information and communicate in connection with our services.
Some WhatsApp conversations may be handled or assisted by Nesti or another AI-enabled service. Where this happens, the AI provisions above apply. The operator of a messaging service may separately process information in accordance with its own privacy terms.
Marketing using messaging services
Service communications about an enquiry, property or transaction are different from marketing. We will only use WhatsApp or similar electronic messaging services for direct marketing where permitted by applicable law. You can ask us to stop marketing messages at any time.
UK Realty Holdings Ltd administers the central CRM and related data infrastructure used by the Group. Oastcrown Properties Limited also participates in the shared CRM arrangements by agreement, despite not being owned by UK Realty Holdings Ltd or 2911 Holdings Limited.
Information concerning clients, contacts, applicants, properties and transactions may therefore be held in shared systems. This enables the participating businesses to maintain accurate records, avoid unnecessary duplication, provide continuity of service, understand relevant client relationships, manage referrals, support compliance, maintain marketing preferences and opt-outs and administer their businesses.
Authorised personnel within Oastcrown Properties Limited, PCL Properties Ltd, FG Property Partners Ltd and UK Realty Holdings Ltd may have access where reasonably necessary for their role and the relevant lawful purpose.
Storage within a shared system does not mean every participating company may use every record for any purpose. Responsibility for processing depends upon why and how the information is being used. Appropriate contractual and data-sharing arrangements are maintained between participating businesses where required.
Some services involve Partners, consultants or other property advisers working with or through one of the businesses covered by this Policy. Depending upon the arrangement, an adviser may operate under the responsibility of a controller, act as a separate controller for particular information or act jointly with one or more controllers.
Where this distinction is material to you, appropriate information will be provided. You may contact dataprotection@ukrealty.co.uk about a privacy matter relating to a service provided through one of our Partners or advisers.
UK Realty Holdings Ltd is the exclusive UK member of Forbes Global Properties. The Kay & Co, Marler & Marler and UK Forbes Global Properties brands participate in the Forbes Global Properties network, enabling international property marketing, introductions and referrals.
Where relevant to a client instruction, enquiry or transaction, we may share appropriate information with FGP, LLC, relevant Forbes entities where appropriate, another independent member of Forbes Global Properties, an overseas property agent or another relevant professional adviser.
This may occur where you wish to acquire property overseas, an overseas buyer is interested in a UK property, you ask us to introduce you to another agent, a property is being marketed internationally or another network member refers a client or property to us.
We limit information shared to what is reasonably necessary. Members of Forbes Global Properties are generally independent businesses and may act as separate controllers. Their own privacy policies and applicable local laws may apply.
We do not sell personal information. Where appropriate, we may share it with:
We may also disclose information in connection with a genuine financing, investment, restructuring, acquisition or sale involving one of the businesses, subject to appropriate safeguards.
Our technology providers, international clients and global property network mean that information may sometimes be transferred to or accessed from outside the United Kingdom.
This may happen through international property referrals, where overseas clients or properties are involved, through an overseas professional adviser, through communications, cloud or AI technology providers or through another service provider operating internationally.
Where UK international-transfer rules apply, we use an appropriate lawful mechanism. Depending upon the circumstances, this may include UK adequacy regulations, the UK Extension to the EU-US Data Privacy Framework where applicable, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses or another lawful transfer mechanism.
You may contact us for more information about safeguards relating to a particular transfer.
We may contact clients, former clients, applicants and other contacts with information we reasonably believe may be relevant. This may include properties for sale or rent, off-market opportunities, property alerts, market updates, research and commentary, invitations, events, news and relevant property services.
Marketing may be sent by email, SMS, WhatsApp, telephone or other electronic communications. We comply with applicable direct-marketing and electronic-communications rules. Where consent is required, we will obtain it. Where applicable law permits us to contact an existing customer about similar services without obtaining fresh consent, we will only do so where the relevant conditions are satisfied.
Stopping marketing
You can stop direct marketing at any time by using an unsubscribe link, replying to an appropriate message, telling a member of our team or contacting dataprotection@ukrealty.co.uk.
You have an absolute right to object to the use of your personal information for direct marketing.
If you opt out, we may retain limited information on a suppression list so that your choice continues to be respected. A marketing opt-out does not prevent us contacting you about an active enquiry, transaction, tenancy, managed property, requested service or legal obligation.
Our websites use cookies and similar technologies. Cookies are small files or pieces of information stored on or accessed from your device. Similar technologies may include pixels, tags, local storage and other identifiers.
Strictly necessary technologies
These are required for website security, operation or functionality requested by you. They may include technologies used to secure the website, maintain website functionality, remember privacy choices and provide services specifically requested by the user. Where permitted by law, these may operate without consent.
Analytics technologies
These help us understand how our websites are used, including pages visited, navigation, referral sources, usage trends and technical problems. Where consent is required, these technologies will not operate until the appropriate choice has been made.
Marketing technologies
These may be used to measure advertising, understand marketing engagement, create audiences and deliver or measure relevant advertising. Where consent is required, these technologies will not operate until you choose to accept them.
Your choices
When you first visit one of our websites you will be given the option to Accept all, Reject non-essential or Manage preferences. You may change your choices at any time using the Cookie Settings link available on the website. The Cookie Settings facility should provide the current list of cookies and similar technologies used by the relevant website, including their purpose, provider and duration.
Our properties and marketing may appear on third-party property portals, social-media platforms and other websites. Where you interact directly with those services, their operators may process personal information independently of us. Their own privacy policies will apply.
Our websites may also contain links to third-party websites. We are not responsible for an independent third party’s privacy practices merely because we provide a link to its service.
We use technical and organisational measures designed to protect personal information against accidental loss, misuse, unauthorised access, unauthorised disclosure, alteration and destruction.
Measures may include access controls, user permissions, authentication, technology security, staff policies and training, supplier controls, contractual safeguards, incident-management procedures and backup and recovery arrangements. Access is restricted according to business need. No electronic communication or information system can be guaranteed to be completely secure.
We retain personal information only for as long as reasonably necessary. Retention periods take account of the nature of our relationship with you, the service provided, whether a property, transaction, tenancy or management relationship remains active, anti-money laundering requirements, tax and accounting requirements, regulatory requirements, relevant legal limitation periods, complaints, disputes and legal claims, the sensitivity of the information and whether there remains a legitimate business need for it.
Different categories are therefore retained for different periods. For example, compliance information may need to be retained for prescribed legal periods; transaction records may need to be retained after completion; property-management information may be retained during and following the management relationship; raw telephone recordings are kept only as long as reasonably necessary for training and monitoring; information relevant to a complaint or claim may be retained until the matter and relevant limitation periods have concluded; and limited suppression information may be kept after a marketing opt-out.
When information is no longer required, it will be deleted, destroyed or anonymised where appropriate.
We do not currently use solely automated processing to make decisions about individuals that have legal or similarly significant effects without meaningful human involvement. If this changes in relation to a service you use, we will provide the additional information required by law.
Depending upon the circumstances, you may have rights to:
To exercise a right, contact dataprotection@ukrealty.co.uk. We may need information to verify your identity and understand your request. Your legal rights are subject to conditions and exemptions and therefore do not apply in every circumstance.
If you are concerned about how we have collected, used, stored or shared your information, please contact dataprotection@ukrealty.co.uk and mark your correspondence “Data Protection Complaint” where possible.
We will provide a clear route for raising the complaint, acknowledge a data protection complaint within 30 days, investigate it appropriately and without undue delay, keep you appropriately informed and communicate the outcome without undue delay.
You also have the right to complain to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113. We would appreciate the opportunity to address your concern directly first.
We may update this Policy to reflect changes in our companies and brands, services, technology, use of artificial intelligence, suppliers or applicable law. The current version will always be available at www.ukrealty.co.uk/privacy.
Data Protection Contact
UK Realty Holdings Ltd
Aston House
Cornwall Avenue
London N3 1LF
dataprotection@ukrealty.co.uk