PRIVACY POLICY

This privacy policy explains who we are, what personal information we collect about you, why we collect it, how we use it, who we share it with, and what rights you have over it. We have written it in plain English. If anything is unclear, please contact us using the details at the end of this page.

1. Who we are

For the purpose of UK data protection law, the data controller is:

Magna Partners Ltd
Company number: 13073115
Registered office: 45 Nork Way, Banstead, England, SM7 1PB
Trading address: Clockwise, 30 Tweedy Road, Bromley, BR1 3FE
Email for data protection enquiries: compliance@magnapartners.co.uk
General contact: info@magnapartners.co.uk · 020 3880 6240

This policy applies to magnapartners.co.uk, buytolet.magnapartners.co.uk, and any other website or sub-domain we operate where this policy is linked.

2. What personal information we collect

The categories of personal information we collect depend on how you interact with us. They include:

Information you give us directly

• Identity and contact details: name, email address, telephone number, and (for some products) postal address
• Investment information: the amount of capital you have available to invest, how you intend to fund your investment (cash, mortgage, or combination), and similar information you share to help us understand whether what we offer is suitable for your situation
• Self-certification declarations: if you enquire about loan note investments, we collect declarations confirming your status as a High Net Worth Individual or Sophisticated Investor, together with evidence supporting that status
• Correspondence: the content of emails, letters, calls, and messages you send us

Information collected automatically when you use our website

• Technical data: IP address, browser type and version, device type, operating system, and approximate location (derived from IP)
• Usage data: pages visited, time spent on pages, links clicked, referring source, and similar information about how you interact with our website
• Cookies and similar technologies: see Section 9 below

Information from third parties

• Advertising platforms: if you click on one of our adverts on Meta (Facebook/Instagram) or Google, we may receive limited information about that interaction including the campaign source, demographics where provided, and conversion event data
• Public sources: Companies House records, Land Registry data, and similar public registers, where relevant to our work

3. Why we collect it and our legal basis

UK data protection law requires us to identify a lawful basis for each thing we do with your personal information. Here is what we do and why:

What we do	Lawful basis
Respond to your enquiry, provide the information you've requested (such as our investor brochure), and arrange consultation calls	Performance of pre-contract steps you have requested, and our legitimate interests in operating our business
Send you our brochure and follow up with you about your enquiry	Your consent (when given via the form), and our legitimate interest in following up on enquiries we have received
Process self-certification declarations for loan note investors	Compliance with our regulatory obligations under the Financial Promotion Order, and your consent
Send you marketing communications about our services and new opportunities	Your consent (you can withdraw it at any time), or in some cases, our legitimate interest where you have previously enquired about similar services and have not opted out (the "soft opt-in" rule)
Show you advertisements on Meta, Google, and other platforms (including retargeting)	Your consent via our cookie banner (where applicable), and our legitimate interest in marketing our services
Improve our website and services, analyse user behaviour, and produce internal reporting	Our legitimate interest in operating and improving our business
Comply with legal obligations (tax, anti-money-laundering checks where required, responding to lawful requests from regulators or law enforcement)	Compliance with legal obligations
Detect, investigate, and prevent fraud or other unlawful activity	Our legitimate interest in protecting our business and our clients

4. Who we share it with

We share your personal information with carefully chosen third parties who help us operate our business. We have written agreements with each of them which set out their obligations to protect your personal information. The main categories are:

Service providers (data processors)

• HubSpot — our customer relationship management system, hosted on the EU instance. All contact and enquiry data is stored in HubSpot. HubSpot data processing terms.
• Calendly — for scheduling consultation calls. When you book through Calendly, your name, email, and any details you provide pass to Calendly under their privacy policy.
• WordPress hosting and our IT providers — for the technical operation of our website.
• Email infrastructure — for sending and receiving emails.
• Professional advisors — including our solicitors, accountants, and (where relevant) compliance consultants, where they need information to advise us.

Advertising and analytics partners

• Meta Platforms (Facebook, Instagram) — via the Meta Pixel installed on our website, where you have consented through our cookie banner. This allows us to measure ad performance and show you relevant adverts on Meta platforms. Meta privacy policy.
• Google — via Google Tag Manager, Google Ads, and Google Analytics, where you have consented through our cookie banner. Google privacy policy.

Property partners

• Property developers — if you proceed with an investment, we will share the information necessary to facilitate the transaction (typically your name, contact details, and reservation form information) with the relevant developer.
• Mortgage brokers and solicitors — where you ask us to introduce you, with your consent.

Legal and regulatory recipients

• Regulators, law enforcement, and courts — where we are legally required to disclose information, including in response to a valid information request from the Financial Conduct Authority, HMRC, the police, or a court.

We do not sell your personal information to anyone.

5. International data transfers

Most of your personal information is stored within the UK or European Economic Area. Some of our service providers (notably parts of Meta's and Google's infrastructure) may transfer or store data outside the UK and EEA, including in the United States.

Where this happens, we rely on appropriate safeguards permitted by UK data protection law, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU-US Data Privacy Framework, depending on the recipient. If you would like more information about the specific safeguards in place, please contact us at compliance@magnapartners.co.uk.

6. How long we keep it

We keep personal information for as long as we have a legitimate reason to do so. In practice this means:

• Active enquiries and clients: we retain your information while we are actively in contact with you, and afterwards in case you come back to us.
• Records you ask us to delete: if you ask us to remove your data and we have no overriding legal reason to keep it, we will delete it from our active systems within 30 days of your request.
• Records we are legally required to keep: some records (for example tax records, anti-money-laundering records, and certain regulatory records relating to financial promotions) must be retained for periods set by law, typically six years.
• Backup copies: some data may persist in routine backup or archival storage for a limited period after deletion from active systems.

7. Your rights

You have the following rights under UK data protection law:

• Right of access — to ask us for a copy of the personal information we hold about you.
• Right to rectification — to ask us to correct information that is inaccurate or incomplete.
• Right to erasure — to ask us to delete your personal information, in certain circumstances.
• Right to restrict processing — to ask us to limit how we use your information, in certain circumstances.
• Right to data portability — to ask us to provide your information in a structured, machine-readable format, or to transmit it to another controller.
• Right to object — to object to our use of your information, including objecting to direct marketing at any time.
• Right to withdraw consent — where we rely on your consent, to withdraw it at any time. Withdrawing consent does not affect the lawfulness of any processing we did before you withdrew it.
• Rights in relation to automated decision-making — we do not currently make decisions about you based solely on automated processing.

To exercise any of these rights, email us at compliance@magnapartners.co.uk. We will respond within one month. If your request is particularly complex or we receive a high volume of requests, we may extend that by up to two further months and will tell you within the first month if so.

We will not charge a fee unless your request is "manifestly unfounded or excessive," in which case we may charge a reasonable fee or refuse to act on the request, and tell you why.

8. Marketing communications

We will only send you marketing communications where you have consented (typically by ticking a box on a form or by submitting an enquiry to us), or where we have a legitimate interest in doing so under the "soft opt-in" rule (where you have enquired about a similar service and have not opted out).

You can unsubscribe at any time:

• By clicking the "unsubscribe" link in any marketing email we send you
• By emailing compliance@magnapartners.co.uk

Unsubscribing from marketing does not stop us sending you communications related to a specific transaction or enquiry you have made (for example, the brochure you requested or follow-up about a property you've viewed).

9. Cookies and similar technologies

Our website uses cookies and similar technologies to help the site work, to understand how visitors use it, and (with your consent) to support our advertising. Cookies fall into the following categories:

Type	What they do
Strictly necessary	Required for the website to function (for example, security, basic navigation, form submissions). These are always on.
Analytics	Help us understand how visitors use our site so we can improve it. Examples: Google Analytics. Set only with your consent.
Advertising	Allow us to measure the performance of our advertising and show you relevant adverts on Meta and Google platforms. Examples: Meta Pixel, Google Ads conversion tags. Set only with your consent.
Functional	Remember choices you have made (for example, scheduling preferences). Set only with your consent.

You can manage your cookie preferences via the cookie banner that appears when you first visit our site, or by clearing cookies in your browser. You can also manage cookies and similar technologies directly in most browsers.

10. Keeping your data secure

We take the security of your personal information seriously. We use technical and organisational measures including encrypted connections (HTTPS), access controls on our systems, strong password requirements, regular security reviews, and contracts with our processors that require them to maintain appropriate security.

If you suspect any misuse, loss, or unauthorised access to your personal information, please contact us immediately at compliance@magnapartners.co.uk.

11. Children's data

Our services are not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe we have inadvertently collected information from a child, please contact us and we will delete it.

12. Links to other websites

Our website may contain links to third-party websites (including property developers' sites, partner sites, and social media). We are not responsible for the privacy practices of those sites. We recommend you read their privacy notices before sharing personal information.

13. Changes of business ownership

If we sell or transfer all or part of our business, the personal information we hold may be transferred to the new owner or to a prospective purchaser, on the same terms set out in this policy. We will take reasonable steps to make sure your personal information continues to be protected.

14. Changes to this policy

We may update this privacy policy from time to time to reflect changes to the law, our business, or our practices. The "Last updated" date at the top of this page will tell you when the most recent change was made. If we make material changes, we will draw them to your attention.