Privacy Policy

SWPI Consultancy Ltd (company number 17310962), registered office 66 Paul Street, London, EC2A 4NA, is the controller of the personal information described in this notice. We trade as SWPI Consultancy and provide property sourcing, investment consultancy, seller and portfolio acquisition services, and the Co-Source sourcer portal.

This notice applies when you visit our website, contact us, register investment criteria, enquire about or sell a property, view an opportunity, join or use Co-Source, submit a deal, or otherwise deal with us. Privacy enquiries and rights requests should be sent to SWPI@SWPIConsultancy.co.uk.

We use SOURCEFOLIO, a separate software service, for investor onboarding, investment criteria, relationship and enquiry records, deal presentations, videos and investor portals. SOURCEFOLIO only holds information that an investor, seller or other user submits through the SWPI forms, onboarding questions or portal fields on that platform. When you follow one of our SOURCEFOLIO links and provide information for SWPI, SWPI decides why that information is collected and how it is used for our property sourcing business. SOURCEFOLIO processes and hosts that information as our technology service provider, subject to its own terms and privacy information.

SOURCEFOLIO also processes limited information for its own purposes as an independent service provider, such as platform security and operation. You can read its current notices at www.sourcefolio.uk. Questions about SWPI’s use of your information should still be directed to us.

• Identity and contact information: name, email address, telephone number, company or trading name and professional contact details.
• Investor information: budget, finance position, preferred locations, strategies, property types, timescales, experience, investment criteria, enquiries, interests and communication records.
• Seller, homeowner and landlord information: property or portfolio address, property type, ownership or selling circumstances, condition, timescale, enquiry details and information needed to arrange a call, viewing or offer.
• Sourcer and compliance information: company website, areas covered, deal types, redress-scheme details, anti-money-laundering registration details and information supplied to demonstrate compliance.
• Deal and property information: addresses, descriptions, tenure, condition, purchase and refurbishment figures, values, rents, calculations, notes, links, photographs, PDFs, video links and other supporting material.
• Co-Source administration information: account status, submission and decision history, workflow events, accuracy strikes, badges, restrictions and minimum blocklist records.
• Account and security information: account identifier, sign-in and authentication events, password-reset activity and access logs. Passwords are handled by our authentication provider; SWPI does not receive or store readable passwords.
• Technical information: IP address, device, browser, operating system, approximate location, pages or features accessed, timestamps, performance and security logs.
• Correspondence and transaction information: emails, support requests, call notes, introductions, viewing or offer information and records needed to progress or document a property transaction.

Our ordinary forms, CRM records and upload areas are not designed for highly sensitive personal information. Unless we expressly request it through an appropriate secure process, do not submit or upload:

• passwords, authentication codes or security answers;
• bank account details, payment card details or online-banking information;
• passport copies, driving licences, government identifiers or other identity documents;
• medical information, biometric data, criminal-offence data or other special-category data; or
• personal information about a vendor, tenant, investor or other person that is not necessary and lawful for the relevant enquiry or transaction.

If identification, source-of-funds or anti-money-laundering evidence is later required, we or an appropriate regulated professional will explain the approved way to provide it.

We receive information directly from you through this website, email, calls, Co-Source and SWPI’s SOURCEFOLIO forms and portals. We may also receive relevant information from sourcers, sellers, investors, agents and professionals involved in a transaction; from public sources such as Companies House, HM Land Registry, property portals and professional registers; and from our technology and communication providers.

• To respond to enquiries, arrange calls and viewings, assess property circumstances and put forward offers — steps taken at your request and our legitimate interests in operating our business.
• To record investor criteria, match and introduce suitable opportunities, administer access to deal information and communicate about relevant properties — steps toward a contract, performance of a contract and our legitimate interests.
• To assess, verify, underwrite, market and progress submitted property opportunities, including due diligence and communications with investors and professional advisers — contract and legitimate interests.
• To create and administer Co-Source accounts, profiles, submissions, workflows and fee records — performance of our agreement with sourcers.
• To check compliance, accuracy and misuse; issue strikes; restrict accounts; and maintain minimum blocklist records — our legitimate interests in protecting investors, sellers, SWPI and the integrity of our services.
• To provide service messages, respond to support requests, maintain records and establish, exercise or defend legal claims — contract, legitimate interests and legal obligation.
• To protect accounts and systems, investigate suspicious activity, diagnose faults and improve reliability — our legitimate interests and legal obligations relating to security.
• To send marketing about our services or opportunities where you have consented, or where another lawful basis permits it. You may opt out at any time.
• To meet tax, accounting, anti-money-laundering, regulatory and other legal requirements where they apply to us or a transaction.

We do not use solely automated decision-making that produces legal or similarly significant effects. Co-Source submissions may be automatically filtered or flagged against our criteria, but SWPI controls the criteria and may review the result.

• SOURCEFOLIO, where you use SWPI's investor onboarding, CRM, deal-presentation or portal services hosted on that platform.
• Our application hosting, database, authentication, secure file-storage, email, analytics, security and technical-support providers.
• Investors, sourcers, sellers and property professionals where necessary for a specific introduction or transaction and where the recipient has a legitimate need to receive it.
• Solicitors, conveyancers, brokers, surveyors, valuers, contractors, accountants, insurers and other professional advisers involved in a transaction or advising us.
• Regulators, law enforcement, courts, tax authorities and other bodies where disclosure is required or permitted by law.
• A buyer, investor or successor in connection with a genuine sale, investment or reorganisation of our business, subject to appropriate confidentiality protections.

We do not sell personal information and do not disclose it to third parties for their own unrelated marketing. Deal and contact information is shared only as reasonably necessary; recipients may become independent controllers for their own professional or transaction obligations.

• Website enquiries that do not lead to an ongoing relationship: normally up to 24 months after the last meaningful contact.
• Active investor, seller, sourcer and business relationship records: for the relationship and normally up to 6 years afterwards.
• Deal submissions, due-diligence records, introductions, decisions and completed transaction records: normally 6 years after the decision or completion, or longer where law or a dispute requires it.
• Strike, restriction and blocklist records: normally up to 6 years after restriction or removal, limited to what is needed to prevent fraud, misrepresentation or repeat misuse.
• Security and technical logs: for a shorter period appropriate to investigation, resilience and legal requirements.
• Backups: retained temporarily on rolling schedules before secure deletion or overwrite.

You may ask us to close an account or delete information. We will delete or anonymise it where required, but may retain records needed for legal duties, fraud prevention, transaction administration, disputes or the exercise or defence of claims.

We use reasonable technical and organisational measures appropriate to the information we handle. These include authenticated access, role-based and row-level access controls, private file storage, encryption in transit, managed infrastructure and restricted staff access. Co-Source users can access their own submissions; authorised SWPI administrators can access records required to operate and review the service.

No online service can guarantee absolute security. You must protect your login details, use a strong unique password and tell us promptly if you believe your account or a shared link has been compromised.

SOURCEFOLIO and some of our hosting, database, authentication, email, analytics or support providers may process information outside the United Kingdom. Where UK data protection law requires safeguards, we rely on UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, or another lawful transfer mechanism, together with appropriate supplementary measures where needed.

Depending on the circumstances, UK GDPR may give you rights to access, correct or erase your information; restrict or object to processing; receive portable data; and withdraw consent. These rights are not absolute. For example, we may retain information needed to comply with law, administer a transaction, prevent misuse or defend a legal claim.

To exercise a right, email SWPI@SWPIConsultancy.co.uk. We may ask you to verify your identity and will normally respond within one month. If your request concerns data entered into an SWPI form on SOURCEFOLIO, contact SWPI first so we can deal with the request as controller.

We and the services we use may place necessary cookies or similar storage for sign-in, security, session continuity and core functionality. Non-essential analytics or marketing cookies are used only where permitted and, where required, with consent. SOURCEFOLIO may use its own cookies when you visit its platform; its own notice explains those cookies. Browser controls can block or delete cookies, but necessary account and portal features may then stop working.

Our services are for adults and business users and are not intended for anyone under 18. We do not knowingly collect children’s information. Contact us if you believe a child has provided information to us.

Please contact us first at SWPI@SWPIConsultancy.co.uk if you have a concern. You also have the right to complain to the Information Commissioner’s Office (registration number ZC195500) at ico.org.uk.

We may update this notice to reflect changes in our services, providers or the law. The date at the top identifies the current version. Where a change materially affects an active account or ongoing service, we will take reasonable steps to notify the affected users.