Privacy Policy

1. Who we are

19 Sourcing Ltd ("we", "us", "our") is a property sourcing company registered in England & Wales, company number 17306899, with its registered office at 124 City Road, London, EC1V 2NX. We are the data controller of the personal data described in this policy and are registered with the Information Commissioner's Office (ICO).

2. The data we collect

We collect personal data when you:

• Submit an enquiry or schedule a callback through our website — name, email address, phone number and the content of your message;
• Engage us as a client — identity and address verification documents, financial information relevant to your property purchase, and correspondence records;
• Communicate with us by email, phone or post.

Our website does not use advertising or tracking cookies. Essential technical data (such as IP address) may be processed by our hosting providers to deliver the site and to protect our forms from abuse.

3. Why we process your data

• To respond to your enquiry or callback request — legal basis: legitimate interests (responding to a request you initiated) and steps prior to entering a contract;
• To perform our sourcing services once engaged — legal basis: performance of a contract;
• To comply with legal obligations, including anti-money laundering checks required of us as an HMRC-supervised business under the Money Laundering Regulations 2017 — legal basis: legal obligation;
• To keep records and defend legal claims — legal basis: legitimate interests.

We do not sell your personal data or use it for third-party marketing.

4. Who we share data with

We share data only where necessary to deliver our services or meet our legal duties: our email and hosting providers (who process data on our instructions), identity verification and AML screening providers, professional advisers (solicitors, accountants, insurers), and regulators or law enforcement where required by law. Where you ask us to, we will share relevant details with your own solicitor, broker or other advisers in connection with a transaction.

5. International transfers

Some of our service providers may process data outside the UK. Where that happens, we ensure appropriate safeguards are in place, such as UK adequacy regulations or standard contractual clauses.

6. How long we keep data

• Enquiries and callback requests that do not become client relationships: up to 12 months;
• Client files, including AML records: at least 5 years from the end of the relationship, as required by the Money Laundering Regulations;
• Accounting records: 6 years, as required by tax law.

7. Your rights

Under UK GDPR you have the right to access your data, correct it, request its erasure, restrict or object to processing, and request data portability. Where processing is based on consent, you may withdraw that consent at any time. To exercise any right, contact us at our registered office address or through the contact form on this website. We will respond within one month.

8. Complaints

If you are unhappy with how we handle your data, please contact us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.

9. Changes to this policy

We may update this policy from time to time. The latest version will always be published on this page with the date of last revision.