Last Updated: 4 November 2025

1. Introduction

5D Group (“we”, “us”, “our”, or “the Company”) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you:

• Visit our website at https://5dgryphon.co.uk/ (the “Website”)
• Use our services
• Contact us for property inquiries
• Create an account on our platform

We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and all applicable data protection laws.

Data Controller:
5D Group
21 Knightsbridge
London SW1X 7LY
United Kingdom

Contact for Data Protection Matters:
Email: info@gryphonam.co.uk
Phone: 020 8040 0590

2. Information We Collect

We collect and process various types of personal data depending on how you interact with our Website and services.

2.1 Personal Information You Provide

When you use our Website or services, you may voluntarily provide us with:

Contact Information:

• Full name
• Email address
• Telephone number(s)
• Postal address
• Preferred method of contact

Property-Related Information:

• Property preferences and requirements
• Budget and financial capacity
• Property search criteria
• Viewing requests and feedback
• Offer details and negotiations

Account Information (if you register):

• Username and password
• Profile information
• Communication preferences
• Saved properties and searches

Transaction Information:

• Property purchase or rental details
• Financial information necessary for transactions
• Bank details (for deposit payments or refunds)
• Proof of funds documentation
• Identity verification documents (required by anti-money laundering regulations)

Communication Records:

• Emails, phone calls, and messages exchanged with us
• Inquiry forms and contact submissions
• Property viewing notes and feedback
• Service feedback and reviews

Professional Information (for landlords/sellers):

• Property ownership details
• Tenancy information
• Maintenance requests
• Financial statements (for property management services)

2.2 Information Collected Automatically

When you visit our Website, we automatically collect certain information:

Technical Information:

• IP address
• Browser type and version
• Operating system
• Device type (desktop, mobile, tablet)
• Screen resolution
• Time zone setting

Usage Data:

• Pages visited and time spent on each page
• Referring website (how you arrived at our site)
• Links clicked
• Property listings viewed
• Search queries performed
• Date and time of visits
• Navigation patterns

Location Data:

• Approximate geographic location (derived from IP address)
• Precise location (only if you grant permission for location services)

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. Detailed information about our use of cookies is available in our Cookie Declaration.

Types of cookies we use:

• Necessary cookies: Essential for website functionality
• Preference cookies: Remember your settings and choices
• Statistics cookies: Help us understand how visitors use our site
• Marketing cookies: Deliver relevant advertisements

You can manage your cookie preferences at any time via our Cookie Declaration page or the cookie banner that appears on your first visit.

2.4 Information from Third Parties

We may receive information about you from:

• Credit reference agencies (for financial assessments)
• Anti-money laundering verification services (required by law)
• Property portals (if you contact us through third-party websites)
• Professional advisors (solicitors, mortgage brokers, surveyors)
• Public records (Land Registry, Companies House)
• Social media platforms (if you contact us via social media)

3. How We Use Your Information

We process your personal data for the following purposes:

3.1 To Provide Our Services

• Property search and matching: Finding properties that meet your criteria
• Arranging viewings: Scheduling and coordinating property viewings
• Processing applications: Handling rental or purchase applications
• Transaction facilitation: Assisting with property sales, purchases, or lettings
• Property management: Managing properties on behalf of landlords
• Maintenance coordination: Arranging repairs and maintenance services
• Account management: Maintaining your user account and preferences

3.2 Communication

• Responding to your inquiries and requests
• Sending property alerts and updates matching your criteria
• Providing customer support
• Notifying you of changes to our services or policies
• Sending service-related announcements
• Following up on property viewings or applications

3.3 Legal and Regulatory Compliance

• Anti-money laundering (AML) checks: Verifying identity as required by the Money Laundering Regulations 2017
• Right to Rent checks: Verifying tenant eligibility (Immigration Act 2014)
• Tax obligations: Complying with HMRC requirements
• Estate agency compliance: Meeting obligations under the Estate Agents Act 1979
• Data protection compliance: Fulfilling our obligations under UK GDPR
• Record keeping: Maintaining records as required by law

3.4 Business Operations

• Analyzing website usage to improve user experience
• Conducting market research and analysis
• Improving our services and developing new features
• Preventing fraud and maintaining security
• Resolving disputes and enforcing our agreements
• Managing complaints and feedback
• Quality assurance and staff training

3.5 Marketing (With Your Consent)

• Sending promotional emails about properties, services, and offers
• Providing personalized property recommendations
• Conducting surveys and requesting feedback
• Inviting you to events or webinars
• Remarketing advertisements on other websites

You can opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email
• Contacting us at info@gryphonam.co.uk
• Updating your preferences in your account settings

4. Legal Basis for Processing

Under UK GDPR, we must have a lawful basis to process your personal data. We rely on the following legal bases:

4.1 Contract (Article 6(1)(b))

Processing is necessary to fulfill our service agreements with you, including:

• Providing property services you’ve requested
• Arranging viewings and managing applications
• Facilitating property transactions
• Managing tenancies

4.2 Legal Obligation (Article 6(1)(c))

Processing is required to comply with legal obligations, including:

• Anti-money laundering verification
• Right to Rent checks
• Tax reporting
• Estate agency regulations
• Health and safety requirements

4.3 Consent (Article 6(1)(a))

Where you have given explicit consent for:

• Marketing communications
• Non-essential cookies
• Processing of special category data (if applicable)

You can withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

4.4 Legitimate Interests (Article 6(1)(f))

Processing is necessary for our legitimate business interests, including:

• Improving our services and website
• Fraud prevention and security
• Network and information security
• Internal administration
• Customer service improvements

We always balance our legitimate interests against your rights and freedoms.

5. Data Sharing and Disclosure

We may share your personal data with third parties in the following circumstances:

5.1 Service Providers and Professional Advisors

We share data with trusted third parties who assist our operations:

Property Transaction Partners:

• Solicitors and conveyancers
• Mortgage brokers and lenders
• Surveyors and valuers
• Property developers and landlords
• Other estate agents (for collaborative sales)

Service Providers:

• IT service providers (website hosting, email services)
• Payment processors
• Customer relationship management (CRM) systems
• Document management platforms
• Identity verification services
• Anti-money laundering verification providers

Professional Advisors:

• Legal advisors
• Accountants and auditors
• Insurance providers

All third-party service providers are required to:

• Process data only as instructed by us
• Implement appropriate security measures
• Comply with UK GDPR requirements

5.2 Regulatory and Legal Requirements

We may disclose your information to:

• Government authorities: HMRC, Home Office, local authorities
• Regulatory bodies: Information Commissioner’s Office (ICO), property ombudsman schemes
• Law enforcement: Police, fraud prevention agencies
• Courts and tribunals: Where legally required

5.3 Business Transfers

If 5D Group is involved in a merger, acquisition, or sale of assets, your personal data may be transferred to the new owner. We will notify you before your data is transferred and becomes subject to a different privacy policy.

5.4 Property Portals and Marketing Platforms

With your consent, we may display property listings on:

• Property portals (Rightmove, Zoopla, OnTheMarket)
• Social media platforms
• Third-party advertising networks

5.5 Other Parties (With Your Consent)

We may share your information with other parties where you have explicitly consented, such as:

• Utility providers for property connections
• Removal companies
• Insurance providers

We do not sell your personal data to third parties for their marketing purposes.

6. Data Security

We implement robust technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

6.1 Security Measures

Technical Safeguards:

• Encryption of data in transit (SSL/TLS)
• Secure servers and databases
• Regular security updates and patches
• Firewall protection
• Access controls and authentication
• Regular security audits

Organizational Safeguards:

• Staff training on data protection
• Confidentiality agreements
• Access restrictions (need-to-know basis)
• Incident response procedures
• Regular policy reviews

6.2 Data Breach Notification

In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the ICO within 72 hours of becoming aware
• Inform you without undue delay if there is a high risk to you
• Take immediate steps to mitigate the breach

6.3 Your Responsibilities

You are responsible for:

• Keeping your account credentials confidential
• Using strong, unique passwords
• Notifying us immediately of any unauthorized account access
• Keeping your contact information up to date

Important: No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7.1 Retention Periods

Active Customers/Clients:

• Retained while you use our services and for a reasonable period afterward

Property Inquiries:

• Retained for up to 2 years after your last interaction (to contact you about similar properties)

Transaction Records:

• Retained for 6 years after transaction completion (legal and tax requirements)

Marketing Consent:

• Retained until you withdraw consent, plus a reasonable suppression period

Anti-Money Laundering Records:

• Retained for 5 years after the business relationship ends (legal requirement)

CCTV Footage (if applicable):

• Retained for up to 30 days (security purposes)

Accounting Records:

• Retained for 6 years (legal requirement)

7.2 Deletion of Data

After the retention period expires, we will:

• Securely delete or anonymize your data
• Remove identifying information where data must be retained for statistical purposes
• Ensure data is deleted from backup systems within a reasonable timeframe

8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

8.1 Right of Access (Article 15)

You have the right to request:

• Confirmation of whether we process your personal data
• A copy of your personal data
• Information about how we use your data

How to exercise: Contact us at info@gryphonam.co.uk. We will respond within one month.

8.2 Right to Rectification (Article 16)

You have the right to request correction of:

• Inaccurate personal data
• Incomplete personal data

How to exercise: Contact us or update your account settings.

8.3 Right to Erasure (Article 17) - “Right to be Forgotten”

You have the right to request deletion of your personal data when:

• Data is no longer necessary for the purposes collected
• You withdraw consent (where consent is the legal basis)
• You object to processing and there are no overriding legitimate grounds
• Data has been unlawfully processed
• Legal obligation requires erasure

Limitations: We may not be able to delete data where we have a legal obligation to retain it (e.g., AML records, accounting records).

8.4 Right to Restriction of Processing (Article 18)

You have the right to request restriction of processing when:

• You contest the accuracy of data (while we verify accuracy)
• Processing is unlawful but you don’t want deletion
• We no longer need the data but you need it for legal claims
• You have objected to processing (while we verify legitimate grounds)

8.5 Right to Data Portability (Article 20)

You have the right to:

• Receive your personal data in a structured, commonly used format
• Transmit your data to another controller

This applies to data processed by automated means based on consent or contract.

8.6 Right to Object (Article 21)

You have the right to object to:

• Processing based on legitimate interests: We must stop processing unless we can demonstrate compelling legitimate grounds
• Direct marketing: We must stop immediately
• Profiling: For marketing purposes

8.7 Right to Withdraw Consent (Article 7(3))

Where processing is based on consent, you have the right to withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Website: https://ico.org.uk
Helpline: 0303 123 1113

8.9 How to Exercise Your Rights

To exercise any of these rights:

1. Contact us at info@gryphonam.co.uk
2. Provide sufficient information to verify your identity
3. Specify which right(s) you wish to exercise

We will respond to your request within one month. In complex cases, we may extend this by two additional months, informing you of the extension and reasons.

We will not charge a fee unless your request is manifestly unfounded or excessive.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and provide personalized content.

9.1 Cookie Management

For detailed information about the cookies we use, their purposes, and how to manage them, please visit our Cookie Declaration page.

9.2 Cookie Consent

We use Cookiebot by Usercentrics for cookie consent management in compliance with UK GDPR and PECR (Privacy and Electronic Communications Regulations).

When you first visit our website, you will see a cookie banner allowing you to:

• Accept all cookies
• Reject non-essential cookies
• Customize your preferences by category

9.3 Managing Cookie Preferences

You can change your cookie preferences at any time by:

• Clicking “Manage Cookies” in the website footer
• Visiting our Cookie Declaration page
• Adjusting your browser settings

Note: Disabling necessary cookies may affect website functionality.

9.4 Third-Party Cookies

Some cookies are set by third-party services we use:

• Google Analytics: Website usage statistics (anonymized)
• Social media platforms: If you interact with embedded social content
• Advertising networks: For remarketing (if you’ve consented to marketing cookies)

These third parties have their own privacy policies governing their use of cookies.

10. International Data Transfers

Your personal data is primarily processed and stored within the United Kingdom. However, in some circumstances, your data may be transferred to and processed in countries outside the UK.

10.1 Safeguards for International Transfers

When we transfer data internationally, we ensure appropriate safeguards are in place:

Adequacy Decisions:

• Transfers to countries with UK adequacy decisions (e.g., EEA countries, Switzerland)

Standard Contractual Clauses (SCCs):

• Using UK-approved Standard Contractual Clauses with service providers

Other Mechanisms:

• Binding Corporate Rules
• Certification schemes (where appropriate)

10.2 Service Providers

Some of our service providers may be located outside the UK:

• Cloud hosting providers (may use data centers in multiple locations)
• Email service providers
• Customer support platforms
• Analytics services

We ensure all such providers implement appropriate safeguards and comply with UK data protection standards.

11. Children’s Privacy

Our services are not directed at children under the age of 18. We do not knowingly collect personal data from children.

If we become aware that we have collected personal data from a child under 18 without parental consent, we will take steps to delete that information as quickly as possible.

If you believe we have collected information from a child, please contact us immediately at info@gryphonam.co.uk.

12. Automated Decision-Making and Profiling

12.1 Property Recommendations

We may use automated systems to:

• Suggest properties matching your search criteria
• Send property alerts based on your preferences
• Personalize your website experience

These automated processes do not produce legal effects or similarly significantly affect you.

12.2 Credit and Affordability Checks

For rental applications or property transactions, we may use automated systems to:

• Conduct credit checks
• Assess affordability

These checks may affect whether your application is approved. You have the right to:

• Request human intervention
• Express your point of view
• Contest the decision

12.3 Your Rights

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significantly affect you (Article 22).

13. Third-Party Links

Our Website may contain links to third-party websites, including:

• Property portals
• Mortgage lenders
• Solicitors and conveyancers
• Social media platforms
• Service providers

We are not responsible for the privacy practices of third-party websites. When you leave our Website, we encourage you to review the privacy policy of every website you visit.

Third-party websites have their own privacy policies and terms of use, which govern their collection and use of your information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

14.1 Notification of Changes

Material Changes:

If we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on our Website
• Sending an email to registered users (at the address provided)
• Updating the “Last Updated” date at the top of this policy

We will provide at least 30 days’ notice before material changes take effect.

Non-Material Changes:

For minor updates that do not significantly affect your rights, we will simply update the policy and the “Last Updated” date.

14.2 Review of Changes

We encourage you to periodically review this Privacy Policy to stay informed about how we protect your information.

Your continued use of our Website after changes take effect constitutes acceptance of the revised Privacy Policy.

15. ICO Registration

5D Group is registered with the Information Commissioner’s Office (ICO) as a data controller.

ICO Registration Number: [To be provided - pending registration]

We comply with all applicable data protection legislation and maintain appropriate registration with the ICO for our data processing activities.

16. Contact Information

16.1 General Inquiries

5D Group
21 Knightsbridge
London SW1X 7LY
United Kingdom

Email: info@gryphonam.co.uk
Phone: 020 8040 0590
Business Hours: Monday - Friday, 9:00 AM - 5:30 PM GMT

16.2 Data Protection Inquiries

For questions specifically related to data protection, privacy, or to exercise your rights:

Email: info@gryphonam.co.uk
Subject Line: “Data Protection Inquiry”

We aim to respond to all data protection inquiries within one month of receipt.

16.3 Complaints

If you have concerns about how we handle your personal data, please contact us first. We take privacy concerns seriously and will work to resolve any issues.

If you are not satisfied with our response, you have the right to lodge a complaint with:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Website: https://ico.org.uk
Helpline: 0303 123 1113
Email: casework@ico.org.uk

Appendix: Glossary of Terms

Personal Data:

Any information relating to an identified or identifiable natural person.

Processing:

Any operation performed on personal data, including collection, storage, use, disclosure, and deletion.

Data Controller:

The entity that determines the purposes and means of processing personal data (5D Group).

Data Processor:

An entity that processes personal data on behalf of the data controller (our service providers).

Consent:

Freely given, specific, informed, and unambiguous indication of agreement to processing of personal data.

UK GDPR:

The UK General Data Protection Regulation, which governs data protection in the United Kingdom.

ICO:

The Information Commissioner’s Office, the UK’s independent data protection authority.

This Privacy Policy is designed to comply with UK GDPR and the Data Protection Act 2018. It should be read in conjunction with our Terms and Conditions and Cookie Declaration.

Last updated: 3 March 2026