Privacy Policy

Effective Date: 17 September 2026
Last Updated: 17 September 2026

1. Introduction

Your privacy is important to us. Ultimate Connexions Sales & Commercials Ltd (“Ultimate Connexions”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal information in accordance with applicable data protection law.

This Privacy Policy explains what personal information we collect, how we collect it, why we use it, the legal bases we rely on, when we may share it, how long we retain it, how we protect it, and the rights available to you.

This policy applies to personal information collected through our business activities, including our website at https://www.ultimateconnexions.co.uk and other websites, systems, forms, communications and services that we own or operate.

2. Who We Are and How to Contact Us

Ultimate Connexions Sales & Commercials Ltd is the data controller for the personal information we process in connection with our business, except where another organisation is the controller for a particular processing activity.

Company details:

Legal name: Ultimate Connexions Sales & Commercials Ltd
Registered/business address: 23 Wellington Street, Luton, Bedfordshire, LU1 2QH
Company registration number: 10805879
ICO registration number: ZA589606
Telephone: 01582 487900
Website: https://www.ultimateconnexions.co.uk

3. Data Protection Contact

Our Data Protection Contact is Mr Rajdvinder Singh Bains. He can be contacted at raj@ultimateconnexions.co.uk or through the company telephone number above.

Mr Rajdvinder Singh Bains is identified in this policy as the company’s Data Protection Contact. He is not described by this policy as a director or as a formally appointed Data Protection Officer (DPO). Where a formal DPO is legally required for a particular processing activity, the relevant contact details will be provided as required.

4. Information We Collect

We may collect and process different types of personal information depending on your relationship with us and the services or transactions involved.

4.1 Log and technical data

When you use our website or online services, we may collect technical information such as your IP address, browser type and version, pages visited, the date and time of visits, time spent on pages, other visit details and technical errors encountered.

4.2 Personal information

Depending on the circumstances, personal information may include: Ultimate Connexions Sales & Commercials Ltd | Privacy Policy | September 2026

Full name, title and, where relevant, previous names;
Date of birth;
Email address and telephone/mobile number;
Home, mailing, current, previous or other relevant addresses;
Property addresses connected with a sale, purchase, letting, management, remortgage or other transaction;
Bank and payment details where required for a transaction or payment;
Passport, driving licence and other identification details;
Occupation, employer or business details;
National Insurance number where lawfully required for a particular purpose;
Company and directorship information where relevant to a business transaction;
Credit, affordability, identity and fraud-prevention information;
Correspondence, communications, instructions, enquiries and records of interactions with us;
Information contained in tenancy agreements, management agreements, sales memoranda, Heads of Terms and related property documentation; and
Other information reasonably

5. How We Collect Personal Information

We may collect personal information directly from you and, where necessary and lawful, from other sources.

When you contact us by telephone, email, social media, website, post or in person;
When you complete an application, registration form, enquiry form or other document;
When you instruct us or enter into an agreement with us;
When you provide information in connection with a property transaction;
From landlords, tenants, buyers, sellers, guarantors, occupiers and other transaction participants;
From solicitors, professional advisers, property owners, agents, contractors and other parties involved in a transaction;
From credit reference agencies, identity verification providers and fraud-prevention services where appropriate;
From publicly available sources, including Companies House, property-related public records, business websites and professional networking or similar public sources, where relevant;
From third-party service providers supporting our business and compliance processes; and
Through our website, including cookies and technical/log information.

Where personal information is obtained from another source rather than directly from you, we will provide the privacy information required by applicable law, subject to any lawful exception.

6. How We Use Personal Information

We may collect, use and process personal information for the following purposes:

To provide, administer and support our estate agency, commercial agency, property and related services;
To communicate with you about enquiries, instructions, properties, applications and transactions;
To assess and progress lettings, sales, purchases, management arrangements, tenancy arrangements and other property transactions;
To prepare and administer tenancy agreements, management agreements, sales memoranda, Heads of Terms and other documents;
To carry out identity verification, credit checks, affordability checks and fraud-prevention checks where appropriate;
To comply with legal, regulatory, contractual, accounting and reporting obligations;
To maintain accurate internal records and administer our business;
To manage payments, invoices, deposits and other financial or transactional matters;
To protect the confidentiality, integrity and availability of our systems and information;
To prevent, detect and investigate fraud, misuse, unauthorised access and other security incidents;
To analyse website use, conduct market research and support business development;
To send advertising, marketing or promotional information where permitted by law and, where required, with your consent;
To maintain and improve our website, systems and services; and
To establish, exercise or defend legal rights and claims.

7. Lawful Bases for Processing

We will only process personal information where we have a lawful basis to do so. Depending on the circumstances, this may include:

Performance of a contract – where processing is necessary to enter into or perform a contract or agreement with you;
Legal obligation – where processing is necessary for us to comply with a legal or regulatory obligation;
Legitimate interests – where processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms;
Consent – where we ask for and rely on your consent, including for certain direct marketing activities; and
Other lawful bases available under applicable data protection law where relevant to the particular processing.
Where we rely on legitimate interests, we consider the purpose of the processing, whether it is necessary and the effect on individuals’ rights and freedoms. We keep appropriate records of relevant assessments where required.

8. Our Legitimate Interests

Our legitimate interests may include operating and developing our business, providing and administering property services, fulfilling contracts, maintaining system and data security, preventing and detecting fraud, managing risk, carrying out audits and compliance activities, protecting confidential information and maintaining the integrity of credit-reference and identity-verification processes.

We will balance these interests against your privacy rights and will not rely on legitimate interests where your rights and freedoms override those interests.

9. Credit Reference, Affordability and Identity Checks

Where appropriate, and where lawful, we may carry out credit reference, affordability, identity verification and fraud-prevention checks in connection with property transactions, applications, contractual relationships and other legitimate business purposes.

We may obtain information through Creditsafe Business Solutions Limited (“Creditsafe”). Creditsafe may use TransUnion International UK Limited as a data partner for consumer credit and identity information.

The information obtained may include identity information, credit commitments, payment history and public-record information. It may be used for purposes including assessing creditworthiness or affordability, verifying identity, preventing fraud and meeting applicable legal and regulatory obligations.

Creditsafe Business Solutions Limited is stated in the information supplied to us as FCA firm reference number 742313. TransUnion International UK Limited is stated as FCA firm reference number 805757.

Further information is available in the relevant transparency and privacy notices provided by Creditsafe and TransUnion:
Creditsafe Privacy/Transparency Notice: https://www.creditsafe.com/gb/en/legal/transparency-notice-customer-supplier.html
TransUnion Credit Reference Privacy Notice: https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference
TransUnion Bureau Privacy Notice: https://www.transunion.co.uk/legal/privacy-centre/pc-bureau

10. Categories of Personal Information Used for Credit and Risk Processes

Identity data – name, title, date of birth and identifiers;
Contact data – postal address, email address and telephone number;
Account and access data – user or account identifiers and relevant authentication information;
Professional/business data – occupation, employer, company and business contact information where relevant;
Financial and transactional data – payment, billing and transaction information where necessary;
Technical and usage data – IP address, device, browser, operating system, access logs and usage information;
Security and audit data – system logs, monitoring records, access records and incident information;
Communications data – correspondence, emails and records of interactions; and
Compliance and risk data – information required for due diligence, regulatory, audit, identity, fraud-prevention and risk-management purposes.

11. Property Transaction and Third-Party Disclosure

We act as estate and commercial agents and, depending on the transaction, may need to share relevant personal information with other parties so that a transaction or service can proceed.

Examples include information required for tenancy agreements, management agreements, credit checks, utility arrangements, sales memoranda, Heads of Terms and related property documentation.

Information that may be disclosed, where relevant and lawful, includes:

Full names, including previous names where relevant;
Date of birth;
Address and contact information;
Bank and payment information where necessary;
Addresses connected with a sale, purchase or remortgage;
Passport, driving licence and other identification details;
Occupation and business information;
National Insurance number where lawfully required;
Information necessary for searches, credit checks or identity verification; and
Other information reasonably necessary to complete or administer the relevant transaction.

We will only disclose information where there is a lawful basis and the disclosure is reasonably necessary for the relevant service, transaction, legal requirement or legitimate business purpose.

12. Who We May Share Information With

Depending on the circumstances, recipients or categories of recipients may include:

Landlords, tenants, buyers, sellers, guarantors, occupiers and other parties directly involved in a property transaction;
Solicitors and other professional advisers;
Credit reference, identity verification and fraud-prevention providers;
Banks, building societies and other financial institutions where necessary;
Insurance companies and relevant insurance providers;
Utility companies and service providers where required for a transaction or property service;
Property owners, occupiers and other relevant property stakeholders;
IT, software, hosting, communications and technical service providers;
Records management and secure archive/storage providers;
Regulators, government bodies, courts, law enforcement and other authorities where required or permitted by law; and
Other carefully selected suppliers and business partners where disclosure is necessary and lawful.

We do not disclose personal information to third parties for their own marketing or promotion of their products or services unless permitted by law and, where required, with your consent.

13. Special Category and Sensitive Information

We do not routinely require special category personal data for ordinary estate agency or commercial agency activities. If such information is provided to us or becomes necessary for a particular lawful purpose, we will only process it where a lawful basis and any additional condition required by applicable data protection law are satisfied.

You should only provide information that is relevant to the service or transaction unless we specifically request additional information for a lawful purpose.

14. International Transfers

Our systems, service providers or business partners may process or store information outside the United Kingdom or, where applicable, outside the UK/European Economic Area. Where personal information is transferred internationally, we will take appropriate steps to ensure that the transfer is lawful and that appropriate safeguards are in place.

An adequacy decision where one applies;
Appropriate contractual safeguards, including approved Standard Contractual Clauses or an International Data Transfer Agreement where applicable; and
Other lawful transfer mechanisms or safeguards recognised by applicable data protection law.

15. Security

We take commercially reasonable and appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration, disclosure or destruction.

These measures may include access controls, password protection, secure systems, appropriate supplier controls, restricted access to information, secure storage and appropriate monitoring and review.

No electronic transmission or storage system can be guaranteed to be completely secure. Where a personal data breach occurs, we will assess and respond to it in accordance with applicable law, including any notification obligations that apply.

You are responsible for keeping any passwords or access credentials issued to you confidential and should notify us promptly if you believe they have been compromised.

16. Retention – How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide services, complete transactions, maintain business records, resolve disputes, establish or defend legal claims and comply with legal, regulatory, accounting or reporting obligations.

The exact retention period may vary depending on the type of information and the circumstances. When information is no longer required, we will securely delete it, destroy it or anonymise it where appropriate.

Credit-reference and affordability information will be retained only for as long as reasonably required for the relevant purpose and applicable legal, regulatory or record-keeping requirements.

17. Provision of Personal Information – What Happens If You Do Not Provide It

Some personal information is necessary for us to enter into or perform a contract, progress a property transaction, conduct identity or fraud checks, comply with legal or regulatory requirements, administer payments or maintain required business records.

Where information is necessary and you do not provide it, we may be unable to enter into or perform an agreement, complete a transaction, conduct required verification, provide a service, or may need to delay, restrict or decline the relevant service or transaction.

Information used only for optional marketing purposes is not generally required to enter into or perform a contract, and where consent is the lawful basis you may withdraw that consent.

18. Automated Decision-Making and Profiling

We may use automated systems or tools to support processes such as credit and affordability checks, fraud prevention, identity verification, security, risk assessment and record management.

Such systems may analyse information using rules or other methods and may produce indicators, scores or recommendations that help determine the level or speed of review required.

Ultimate Connexions does not intend to make decisions producing legal or similarly significant effects on individuals solely by automated means. Where a decision of that nature is required, appropriate human involvement and review will be applied.

Automated tools may therefore support a decision-making process without being the sole basis for an adverse or similarly significant decision.

19. Your Data Protection Rights

Subject to applicable law and any relevant exemptions or limitations, you may have the right to:

Request access to the personal information we hold about you;
Request correction of inaccurate or incomplete information;
Request erasure of personal information in certain circumstances;
Request restriction of processing in certain circumstances;
Object to processing based on legitimate interests or for direct marketing, subject to applicable law;
Request data portability where the legal requirements for portability are met; and
Withdraw consent where we rely on consent as the lawful basis for processing.

These rights are not absolute and may not apply in every circumstance. For example, we may need to retain or continue processing information to comply with a legal obligation or establish, exercise or defend legal claims.

20. How to Exercise Your Rights

To exercise a data protection right or ask a question about how we use your personal information, contact our Data Protection Contact at raj@ultimateconnexions.co.uk or contact Ultimate Connexions Sales & Commercials Ltd using the details in Section 2.

We may need to request information to verify your identity before responding to a request. This is a security measure designed to prevent personal information being disclosed to the wrong person.

We aim to respond within the period required by applicable data protection law.

21. Direct Marketing

Where permitted by law, we may contact you with information about our services, properties, commercial opportunities, updates or other relevant business communications.

Where consent is required, we will obtain it before sending the relevant marketing communications. You may withdraw consent or opt out of direct marketing communications at any time. Where an unsubscribe facility is provided, you can use it to opt out.

Withdrawing consent for marketing does not affect processing carried out on another lawful basis, such as processing necessary to perform a contract or comply with a legal obligation.

22. Cookies

Our website may use cookies and similar technologies to collect information about website activity, preferences and content interaction.

Cookies may help us understand how our website is used, improve website functionality and support relevant website features. Where applicable, we will provide information about cookies and obtain consent where required by law.

You can also manage cookies through your browser and, where provided, our website cookie controls. Disabling certain cookies may affect website functionality.

23. Children

Our services are not directed specifically at children under 13 and we do not knowingly collect personal information from children under 13 for the purpose of providing services directly to them.

If we become aware that personal information relating to a child has been collected in circumstances where it should not have been, we will take appropriate steps to address the situation.

24. Information From Third Parties

We may receive personal information about you from other people or organisations, including landlords, tenants, buyers, sellers, guarantors, solicitors, professional advisers, credit reference agencies, identity verification providers, fraud-prevention services, public registers and other service providers.

When we obtain personal information from another source, we may process it for the purposes described in this policy and will provide the relevant privacy information required by law. The categories and sources of information may vary according to the transaction or service.

We may combine information received from third parties with information you provide directly to us where this is necessary and lawful.

25. External Websites

Our website may contain links to websites operated by third parties. Those websites have their own privacy policies and terms. Ultimate Connexions does not control third-party websites and is not responsible for their privacy practices. You should review the privacy policy of any external website before providing personal information.

26. Complaints

If you have a concern about how we have handled your personal information, please contact us first so that we can investigate and respond.

You also have the right to complain to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection matters. ICO website: https://ico.org.uk/

We encourage you to contact us first where possible so that we have an opportunity to address your concern.

27. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business processes, services, systems, legal or regulatory requirements or data protection practices.

Where appropriate, we will review and update the policy before introducing a new use of personal information and will bring material changes to individuals’ attention where required.

The current version will be made available through our website or otherwise provided to relevant individuals.

28. Transparency and How This Policy Is Provided

We aim to provide this policy in a concise, transparent, intelligible and easily accessible form using clear and plain language.

Where personal information is collected directly from you, privacy information should be provided at the time the information is collected. Where personal information is obtained from another source, the relevant information should be provided within the period required by applicable law, subject to lawful exceptions.

This policy should be read alongside any more specific privacy information or notices that we may provide for particular services, transactions, forms, website functions or processing activities.

29. Contact Details

If you have any questions about this Privacy Policy, how we process personal information, or your data protection rights, please contact:

Ultimate Connexions Sales & Commercials Ltd

23 Wellington Street

Luton, Bedfordshire

LU1 2QH

Telephone: 01582 487900

Data Protection Contact: Mr Rajdvinder Singh Bains

Email: raj@ultimateconnexions.co.uk

Website: https://www.ultimateconnexions.co.uk

30. Policy Review Record

Previous policy: Effective and last updated 1 August 2022.

This replacement policy: Effective and last updated 17 September 2026.

This version has been prepared using the company’s previous privacy policy as the foundation and incorporating the additional credit-reference, affordability, transparency, lawful-basis, rights, retention, international-transfer, security and automated-decision-making information identified in the Creditsafe requirements supplied to the company.