Pevona Ltd — Privacy Policy
Last Updated: 2025
This document explains how Pevona Ltd collects, uses, and protects your personal information in accordance with the UK General Data Protection Regulation (UK GDPR).
1. Who We Are
Pevona Ltd is the Data Controller for your information.
Registered Address
Pevona Ltd
Flat 14, Burgundy House
25 Liberty Bridge Road
London, E20 1AQ
ICO Registration Number: ZA123456
Data Protection Officer (DPO)
Peter Banyong
Email: Pebans@pevonaltd.co.uk
Phone: +44-203-632-9485
2. Scope of Services
This policy covers personal data processed across all our service lines, including:
- Sales & Lettings Agency (Let-Only, Rent Collection, Full Management)
- Property Management
- Investment & Portfolio Management
- Compliance Services (EPC, EICR, Gas Safety, Licensing, AML/KYC)
- Franchise & Branch Operations
3. Data We Collect
We collect personal data through the following methods:
A. Data You Provide
Information you voluntarily submit to us via forms, emails, or phone:
- Identity Data: Passport, Driving License.
- Contact Data: Name, Email, Phone Number, Current Address.
- Financial Data: Bank details, Proof of funds.
- Property Data: Title deeds, proof of ownership.
B. Data From Third Parties
Information we receive from external verification sources:
- Credit Reference Agencies (for tenant referencing).
- Anti-Money Laundering (AML) Databases.
- Solicitors & Developers.
C. Technical Data
Automated data collection from website interactions:
- IP Address & Browser Type.
- Analytics & Usage Data.
- Cookies.
Notice: Special Category Data
We process sensitive data (such as criminal record checks or Politically Exposed Person status) strictly for AML/KYC compliance and fraud prevention purposes under the lawful basis of substantial public interest.
4. Lawful Bases for Processing
We only process your data when we have a legal ground to do so.
- Performance of Contract: Necessary to fulfill a contract with you (e.g., Tenancy Agreements, processing rent payments, arranging viewings).
- Legal Obligation: Necessary for compliance with the law (e.g., Right to Rent checks, AML checks, HMRC tax reporting).
- Legitimate Interest: Necessary for running our business (e.g., debt recovery, website security, B2B marketing), provided your rights do not override these interests.
- Consent: Where you have given explicit permission (e.g., third-party marketing, optional tracking cookies).
5. How We Use Your Data
We use your data for specific business purposes depending on the service you use:
- Lettings Services: Referencing tenants, drafting agreements, collecting rent, registering deposits, and coordinating maintenance.
- Sales Agency: Verifying ownership, marketing properties, arranging viewings, negotiating offers, and sales progression.
- Compliance Services: Issuing EPC/EICR certificates, Gas Safety checks, and managing licensing applications.
6. Sharing Your Data
We may share your data with the following categories of third parties:
- Professional Advisers: Solicitors, Surveyors, Bankers, Insurers.
- Service Providers: IT/System Administrators, CRM providers, Maintenance contractors.
- Regulators: HMRC, The Property Ombudsman, Local Authorities, Police (upon valid request).
- Internal Group: Franchise branches and Pevona group companies.
International Transfers:
Given our base of international investors, data may be transferred outside the UK. These transfers are protected by Standard Contractual Clauses (SCCs) or Adequacy Decisions.
7. Data Retention
We retain your data only as long as necessary to fulfill the purposes we collected it for.
| Data Type | Retention Period | Reason |
|---|---|---|
| Transaction Records | 7 Years | Tax (HMRC) & Legal Claims |
| AML / ID Checks | 5 Years | Money Laundering Regulations |
| Tenancy Agreements | 6 Years | Limitation Act 1980 |
| Marketing Data | Until Opt-out | Consent / Legitimate Interest |
8. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- 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: Ask us to delete your data where there is no good reason for us to continue processing it (also known as the "Right to be Forgotten").
- Right to Object: Object to processing for direct marketing or where we rely on legitimate interest.
- Right to Restrict Processing: Ask us to suspend the processing of your data.
- Right to Data Portability: Request the transfer of your data to you or a third party.
- Right to Withdraw Consent: Withdraw consent at any time where we are relying on it to process your data.
9. Anti‑Money Laundering & Compliance
Supervision: Pevona Ltd is subject to HMRC AML supervision (Registration/Approval No.: []).
MLRO: Peter Banyong (Nominated Officer) — responsible for AML governance, SAR decisions, and effectiveness reviews.
Our Risk‑Based Approach
We apply documented Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) proportional to risk, supported by a Firm‑Wide Risk Assessment (FWRA). Controls include identity & address verification, beneficial ownership checks (corporate/trust clients), and right‑to‑rent (where applicable).
We conduct sanctions and PEP screening at onboarding and periodically using the HM Treasury consolidated list and electronic tools (e.g., SmartSearch).
We maintain ongoing monitoring of active relationships and retain AML records for a minimum of 5 years after the relationship/transaction ends.
Suspicious Activity Reporting (SAR)
We operate robust SAR procedures: staff report suspicions to the MLRO; the MLRO evaluates and, where required, submits SARs to the National Crime Agency (NCA).
Client Money Controls
We operate designated client accounts under UKALA Client Money Protection (CMP) requirements.
Downloads
- AML Policies, Controls & Procedures (PCP) — AML_PCP.pdf
- Firm‑Wide Risk Assessment (FWRA) — Firm‑Wide Risk Assessment (FWRA)
10. Accessibility (Site‑Wide Statement)
Commitment:
We aim to align with WCAG 2.1 AA across our website.
Features
Keyboard navigation, descriptive alt text, colour contrast, and ARIA landmarks to improve screen‑reader navigation.
Support & Adjustments
If you require reasonable adjustments or assistance to access our website or services, please contact us and we will help.
Contact for accessibility support: admin-pev@pevonaltd.co.uk | +44-203-632-9485
11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact our Data Protection Team.
Address: Flat 14, Burgundy House, 25 Liberty Bridge Road, London, E20 1AQ.
Email: admin-pev@pevonaltd.co.uk
Phone: +44-203-632-9485 | +447944-228811
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been breached. Visit ico.org.uk for more information.