Prime Executives Property Group Limited ("PREPG3", "we", "our", "us") is the data controller responsible for your personal data. We are registered in England and Wales and operate from First Floor, Swan Buildings, 20 Swan Street, Manchester, M4 5JW.
For privacy-related enquiries, contact our Data Protection Officer at privacy@prepg3.co.uk.
2. Information We Collect
We collect personal information that you provide during registration and use of our platform, including:
Identity data: first name, last name, date of birth, and identity documents (passport, driving licence)
Contact data: email address, phone number, and residential address
Employment and financial data: employment status, occupation, employer, annual income range, and source of investment funds
Compliance data: Politically Exposed Person (PEP) status, KYC verification documents, and proof of address
Account data: investor type, investment preferences, and marketing consent
Transaction data: investment activity, payment details, and transaction history
Technical data: IP address, browser type, device information, and usage data collected through cookies and similar technologies
3. Legal Basis for Processing
We process your personal data on the following legal bases under the UK General Data Protection Regulation (UK GDPR):
Contract: to provide our services and manage your investment account
Legal obligation: to comply with anti-money laundering (AML), Know Your Customer (KYC), and financial regulatory requirements, including the Money Laundering Regulations 2017
Legitimate interests: to improve our platform, prevent fraud, and manage our business operations
Consent: for marketing communications and non-essential cookies (you may withdraw consent at any time)
4. How We Use Your Information
We use your personal information to:
Create, manage, and maintain your investor account
Verify your identity and conduct KYC and AML checks as required by law
Assess your employment status, income, and source of funds for regulatory compliance and investment suitability
Conduct enhanced due diligence where you have declared PEP status or where required by our risk assessment procedures
Process investment transactions and send account notifications
Communicate with you about your account, investments, and platform updates
Send marketing communications about new investment opportunities and market insights (only with your consent)
Detect, investigate, and prevent fraudulent or illegal activity
Improve our platform, services, and user experience
5. Data Sharing
We do not sell your personal data. We may share your information with trusted third parties in the following circumstances:
Identity verification providers: to carry out KYC checks and verify your identity documents
AML screening services: to conduct anti-money laundering, sanctions, and PEP screening checks
Payment processors: to process investment transactions securely
Legal and regulatory bodies: where required by law, including the Financial Conduct Authority (FCA), HM Revenue and Customs (HMRC), and the National Crime Agency (NCA)
Professional advisers: including lawyers, accountants, and auditors where necessary
Cloud service providers: who host and process data on our behalf (under strict data processing agreements)
All third-party processors are contractually bound to protect your data and use it only for the purposes we specify.
6. International Transfers
Your data is primarily stored and processed within the United Kingdom and the European Economic Area. Where data is transferred outside these regions (for example, to cloud service providers), we ensure appropriate safeguards are in place, including standard contractual clauses approved by the UK Information Commissioner's Office.
7. Data Security
We implement industry-standard security measures to protect your personal information, including:
Encryption of data in transit (TLS/SSL) and at rest (AES-256)
Multi-factor authentication and strong password requirements
Role-based access controls and audit logging
Regular security assessments and penetration testing
Secure cloud infrastructure with automatic backups
While we take all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.
8. Data Retention
We retain your personal data for as long as your account is active and for a period afterwards as required by financial regulations:
Account and identity data: retained for a minimum of 5 years after account closure, as required by the Money Laundering Regulations 2017
Transaction records: retained for a minimum of 6 years after the relevant transaction, in line with HMRC requirements
KYC and AML records: retained for 5 years after the end of the business relationship
Marketing preferences: retained until you withdraw consent, after which we will delete or anonymise the data within 30 days
9. Your Rights
Under UK data protection law, you have the following rights:
Right of access: request a copy of the personal data we hold about you
Right to rectification: request correction of inaccurate or incomplete data
Right to erasure: request deletion of your data (subject to legal retention obligations)
Right to restrict processing: request that we limit how we use your data
Right to data portability: receive your data in a structured, machine-readable format
Right to object: object to processing based on legitimate interests or direct marketing
Right to withdraw consent: withdraw consent for marketing communications at any time
To exercise any of these rights, contact us at privacy@prepg3.co.uk. We will respond within one month of receiving your request. Please note that some rights may be limited where we have a legal obligation to retain certain data (for example, AML records).
10. Cookies
We use essential cookies to ensure the platform functions correctly and analytics cookies to understand how you use our services. You can manage your cookie preferences through the cookie banner displayed when you first visit our platform. For more details, see our Cookie Policy.
11. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of material changes via email or through a notice on our platform. The "last updated" date at the top of this page indicates when the policy was last revised.
12. Complaints
If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Website: ico.org.uk Helpline: 0303 123 1113
We would appreciate the opportunity to resolve your concerns before you approach the ICO. Please contact us first at privacy@prepg3.co.uk.
13. Contact
For privacy-related enquiries, please contact:
Data Protection Officer Prime Executives Property Group Limited First Floor, Swan Buildings, 20 Swan Street Manchester, M4 5JW Email: privacy@prepg3.co.uk Phone: 01270 906499