Privacy Policy
Last Updated: 07/01/2026
Who we are
This Privacy Policy explains how SwiftSOF (“we”, “us”, “our”) collects and uses personal data in the course of:
operating our website www.swiftsof.com (the “Site”); and
providing AML admin and source-of-funds support services (“Services”) to estate agency clients.
Controller:
For most processing described in this Policy, SwiftSOF acts as a data controller – we decide what personal data we collect and why.
Processor:
When we handle AML documents and information about buyers, sellers and giftors on behalf of an estate agent, that estate agent is the data controller. In those cases, we act as their data processor, following their instructions.
Our details:
Legal name: SwiftSOF Limited
Registered address: 86-90 Paul Street, London, England, EC2A 4NE
Email: info@swiftsof.com
Phone: 02038352381
If you have any questions about this Policy, you can contact us at info@swiftsof.com
2. Who this Policy applies to
This Policy applies to:
Website visitors – people who browse our Site.
Estate agents and their staff – our business contacts and users of our Services.
Clients of estate agents – buyers, sellers, giftors and other individuals whose personal data we process on behalf of estate agents as part of AML admin work.
If you are a buyer, seller or giftor, your main privacy relationship is with your estate agent, who is the data controller for AML purposes. We process your personal data on their instructions; this Policy explains how we handle that data on their behalf.
3. Personal data we collect
3.1 Data we collect from website visitors and business contacts
When you use our Site or interact with us as a business contact, we may collect:
Contact details – name, job title, agency name, email address, phone number.
Correspondence – emails, messages and any other information you choose to share when you contact us or book a call.
Usage data – IP address, browser type, pages visited, time and date of visits, and similar technical data, collected via cookies or analytics tools (see Cookies section / Cookies Policy).
3.2 Data we process for estate agents’ clients (buyers, sellers, giftors)
When an estate agent uses our Services, they may instruct us to process personal data about their clients for AML admin and source-of-funds purposes. This can include:
Identification data – name, date of birth, contact details, nationality, address history.
Identity documents – passport details, driving licence details, copies/scans of ID documents.
Address evidence – bank statements, utility bills, council tax bills and similar documents.
Financial information – bank and savings statements, investment or ISA statements, completion statements from previous property sales, pension or inheritance documents, and similar.
Giftor information – details of family members or other third parties providing gifts (ID details, contact information, basic financial information shown on statements).
Digital verification data – results of ID verification, liveness checks and sanctions/PEP screening performed by third-party tools.
Case metadata – property address, intended transaction value, breakdown of funding sources, and notes on the “money story” that we compile for the estate agent.
We only collect and use this data under the instructions of the estate agent and for the purposes they define in their AML process.
4. How we use personal data and our lawful bases
We must have a lawful basis for each type of processing under UK GDPR.
4.1 Website visitors and business contacts (we act as controller)
We use your personal data to:
Respond to enquiries and provide information about our Services
Data used: contact details, correspondence.
Legal basis: Legitimate interests – our interest in responding to enquiries and promoting our Services (and your interest in receiving a response).
Provide and improve our Site and Services
Data used: usage data, technical logs.
Legal basis: Legitimate interests – operating a secure, effective website and understanding how it is used.
Enter into and perform contracts with estate agency clients
Data used: contact details, agency information, communications.
Legal basis: Contract – necessary to enter into or perform a contract with the agency you represent.
Marketing to business contacts (limited, B2B)
Data used: work contact details, history of interactions.
Legal basis: Legitimate interests – to send relevant information about our Services to estate agency professionals. You can opt out at any time by using the unsubscribe link or contacting us.
We do not use your data to make automated decisions that have legal or similarly significant effects on you.
4.2 Buyers, sellers and giftors (we act mainly as processor)
When we process personal data about buyers, sellers and giftors on behalf of an estate agent:
The estate agent is the controller and determines the lawful basis for processing (typically the agent’s legal obligation to carry out AML checks, plus their legitimate interests).
SwiftSOF acts as a processor. We use the data solely to:
Contact you to explain what documents are needed for AML checks;
Provide secure upload facilities for your documents;
Organise and summarise those documents into an AML/source-of-funds pack for the estate agent;
Run ID/liveness and sanctions/PEP checks using agreed third-party tools;
Provide the results and summaries back to the estate agent.
If you are a client of an estate agent and have questions about the legal basis for processing or your rights, you should usually contact your estate agent first, as the controller.
5. How we share personal data
We may share personal data with:
Estate agencies (our clients) – where necessary to provide our Services and deliver AML packs back to them.
Professional advisers – such as lawyers, accountants or auditors where needed for our business operations.
Service providers / sub-processors – who host our systems, provide secure document storage, email, ID verification, or other IT services. These providers are bound by contracts that require them to protect personal data and only use it according to our instructions.
Regulators or law enforcement – if we are legally required to do so, or to protect our rights, property or safety, or that of others.
We do not sell personal data.
6. International transfers
Some of our service providers may be located outside the UK or may store data on servers outside the UK.
Where this results in a transfer of personal data to a country that is not covered by a UK adequacy regulation, we will put in place appropriate safeguards (such as UK International Data Transfer Agreements or standard contractual clauses) to protect the data, as required by UK data protection law. Association of Taxation Technicians
You can contact us for more information about the countries involved and the safeguards used.
7. How long we keep personal data
We keep personal data only for as long as reasonably necessary for the purposes set out in this Policy, including:
fulfilling the purposes we collected it for;
meeting legal, accounting and reporting requirements; and
dealing with potential disputes.
As a general guide:
Website and enquiry data: we typically keep contact and enquiry records for up to [2 years] after our last meaningful interaction with you, unless we need to keep them longer for legal or business reasons.
Estate agent client data (buyers/sellers/giftors): we keep AML-related documents and data in line with our contracts with each estate agent and their AML record-keeping obligations, which are often at least 5 years from the end of the business relationship or transaction.
When we no longer need personal data, we will delete it or anonymise it in a secure manner.
8. Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, use, loss or disclosure. GOV.UK
These measures include, for example:
encryption of data in transit (HTTPS) and at rest where appropriate;
access controls and authentication for staff;
restricting access to client files on a need-to-know basis;
secure configuration and monitoring of our systems;
staff training on data protection and AML confidentiality;
procedures for responding to suspected personal data breaches.
However, no system can be completely secure. If you have any concerns about the security of your data with us, please contact us using the details above.
9. Your rights
Under UK data protection law, you have certain rights in relation to your personal data. These may include:
Right of access – to obtain confirmation whether we process your personal data and a copy of that data.
Right to rectification – to have inaccurate or incomplete data corrected.
Right to erasure – to ask us to delete your personal data in certain circumstances.
Right to restrict processing – to ask us to restrict use of your data in certain circumstances.
Right to object – to object to processing based on our legitimate interests, in some situations.
Right to data portability – to receive certain personal data in a structured, commonly used format and transmit it to another controller (where applicable).
These rights are not absolute and may be limited, for example where we have legal obligations to keep certain records.
If you are a client of an estate agent (buyer/seller/giftor):
Because we usually act as a processor, you should normally exercise your rights by contacting your estate agent as the data controller. We will assist them in responding to your request.
If you are a website visitor or business contact:
You can exercise your rights by emailing us at info@swiftsof.com. We may need to ask for proof of identity before responding.
10. Cookies and similar technologies
We use cookies and similar technologies on our Site to:
make the Site work properly;
understand how visitors use the Site; and
improve our content and user experience.
Some cookies are strictly necessary for the Site to function and do not require consent. For non-essential cookies (such as analytics), we will ask for your consent where required.
For more details on the cookies we use and how to change your preferences, please see our Cookies Policy.We use cookies and similar technologies on our Site to:
make the Site work properly;
understand how visitors use the Site; and
improve our content and user experience.
Some cookies are strictly necessary for the Site to function and do not require consent. For non-essential cookies (such as analytics), we will ask for your consent where required.
For more details on the cookies we use and how to change your preferences, please see our Cookies Policy.We use cookies and similar technologies on our Site to:
make the Site work properly;
understand how visitors use the Site; and
improve our content and user experience.
Some cookies are strictly necessary for the Site to function and do not require consent. For non-essential cookies (such as analytics), we will ask for your consent where required.
For more details on the cookies we use and how to change your preferences, please see our Cookies Policy.
11. Complaints and contact details
If you have any questions or concerns about how we handle your personal data, please contact us first at:
Email: info@swiftsof.com
Phone: 02038352381
Address: 86-90 Paul Street, London, England, EC2A 4NE
We will do our best to resolve any concerns.
You also have the right to complain to the UK data protection regulator, the Information Commissioner’s Office (ICO), if you are unhappy with how we have used your data.
ICO contact details:
Website: ico.org.uk
Phone: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example to reflect changes in our Services or in data protection law. The updated version will be posted on this page with a new “Last updated” date.
We encourage you to review this page periodically to stay informed about how we handle personal data.