Download Our Policies

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We are committed to providing a professional service to all our clients and customers.  When something goes wrong, we need you to tell us about it.  This will help us to improve our standards.

If you have a complaint, please put it in writing, including as much detail as possible. We will then respond in line with the timeframes set out below (if you feel we have not sought to address your complaints within eight weeks, you may be able to refer your complaint to the Property Redress Scheme to consider without our final viewpoint on the matter).

What will happen next?

· We will send you a letter acknowledging receipt of your complaint within three working days of receiving it, enclosing a copy of this procedure.

· We will then investigate your complaint. This will normally be dealt with by the office manager who will review your file and speak to the member of staff who dealt with you.  A formal written outcome of our investigation will be sent to you within 15 working days of sending the acknowledgement letter.

· If, at this stage, you are still not satisfied, you should contact us again and we will arrange for a separate review to take place by a senior member of staff. 

· We will write to you within 15 working days of receiving your request for a review, confirming our final viewpoint on the matter.

· If you are still not satisfied after the last stage of the in-house complaint procedure (or more than 8 weeks has elapsed since the complaint was first made) you can request an independent review from the Property Redress Scheme without charge.

Property Redress Scheme

Premiere House

1st Floor

Elstree Way

Borehamwood

WD6 1JH

0333 321 9418 

info@theprs.co.uk

https://www.theprs.co.uk/

Please note the following:

You will need to submit your complaint to The Property Redress Scheme within 12 months of receiving our final viewpoint letter, including any evidence to support your case. 

The Property Redress Scheme requires that all complaints are addressed through this in-house complaint procedure, before being submitted for an independent review. 

PL Property Solutions Limited and PLPS Global Limited ("We") are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website (https://plpropertysolutions.com/) you are accepting and consenting to the practices described in this policy. 

For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is PLPS Global Limited of 20-22 Wenlock Road, London, N1 7GU.

Information We may collect from you;

We may collect and process the following data about you:

· Information you give us. You may give us information about you by filling in forms on https://plpropertysolutions.com ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register with us, accept our services, pay for any services provided and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number(s), date of birth, financial and credit card information.

· Information We collect about you. 

With regard to each of your visits to our site We may automatically collect the following information:

· technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; 

· information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. 

· Information We receive from other sources. 

We may receive information about you if you use any of the other websites We operate or the other services We provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies We use and the purposes for which We use them see our Cookie policy.

Uses made of the information

We use information held about you in the following ways:

· Information you give to us. 

We will use this information:

· to provide you with information about other goods and services We offer that are similar to those that you have already purchased or enquired about;

· to provide you, or permit selected third parties to provide you, with information about goods or services We feel may interest you. If you are an existing customer, We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing; 

· to notify you about changes to our service;

· to ensure that content from our site is presented in the most effective manner for you and for your computer. 

· Information We collect about you. 

We will use this information:

· to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

· to improve our site to ensure that content is presented in the most effective manner for you and for your computer; 

· to allow you to participate in interactive features of our service, when you choose to do so;

· as part of our efforts to keep our site safe and secure;

· to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;

· to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

· Information We receive from other sources. 

We may combine this information with information you give to us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

Disclosure of your information

We may share your information with selected third parties including:

· Our Payment Processor;

· Business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you.

· Analytics and search engine providers that assist us in the improvement and optimisation of our site. 

· We do NOT share your data with third party advertisers. This means you will never receive communication directly from a third party through the data you have provided us. From time to time, We will offer promotion of other services from third parties we have selected that We believe complimentary to our business and our offering. Such communications will only ever be sent through our own mailing servers, and no personalised data will not be shared with third parties without your opt in. 

We may disclose your personal information to third parties:

· In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.

· If PL Property Solutions or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

· If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any other agreements; or to protect the rights, property, or safety of PL Property Solutions, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We store your personal data

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us, one of our suppliers or for our Booking Provider and Payment Processor. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. 

Any payment transactions will be made through our Payment Processor who will be responsible for the protection of the information that you provide to them.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us to amend, or delete your data at any time. We encourage you to keep information we hold up to date, such that we can send you emails, opportunities & other marketing from ourselves relevant to you.  You can also exercise the right at any time by contacting us at data@plproperty.solutions. At the entering of such a request, we will aim to delete your information forthwith, and information will be deleted within 30 days of the request, although some data may remain viewable in cached and archived pages of our sites for a period of time. 

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. 

Changes to our privacy policy

Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to data@plproperty.solutions.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at 20-22 Wenlock Road, London, N1 7GU or by emailing data@plproperty.solutions.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address: 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies: 

· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. 

· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. 

· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Please note that third parties (including, for example, our Payment Processor, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.  

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. 

Except for essential cookies, all cookies will expire after 12 months. 

Kindly note that we strictly adhere to all existing Anti-Money Laundering legislation. Therefore, we require every client to provide two forms of identification to verify their full name, residential or business address, date of birth, and registration details with any corporate bodies. 

1. Introduction

PLPS Global Limited is a UK registered company providing investment opportunities that have been packaged especially for the investors needs. The business of the Company is [low] risk in relation to money laundering, however in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we wish to put in place the following anti-money laundering policy which supplements the anti-money laundering training given to all members of staff.

2. Scope of the Policy

The broad definition of money laundering means that potentially anyone could commit a money laundering offence, this includes all employees of the Company, all temporary staff and contractors. 

Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the [low] risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.

All employees must be familiar with their legal responsibilities. Failure to comply with this Policy may lead to disciplinary action.
 

3. What is Money Laundering?

The principal primary legislation is The Proceeds of Crime Act 2002 (POCA), which consolidated, updated and reformed criminal law with regard to money laundering, supplemented by the Terrorism Act 2000 and the Fraud Act 2006.The principal secondary legislation is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019.

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the UK (Section 327 POCA); entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (Section 328 POCA); and acquiring, using or possessing criminal property (Section 329 POCA).

There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

Any member of staff could potentially be caught by the money laundering provisions, if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. This Policy sets out how any concerns should be raised.

4. Money Laundering Reporting Officer (MLRO)

The Company will appoint a MLRO to receive disclosures about money laundering activity and be responsible for anti-money laundering activity within the Company. The officer nominated to do this is Phillip Hall.

The Company will also appoint a deputy MLRO who will be responsible in the absence of the nominated officer. The deputy MLRO is Phillip Hall.

The MLRO will ensure that appropriate training and awareness is provided to new and existing employees / temporary staff / contractors and that this is reviewed and updated as required.

The MLRO will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.
 

5. Suspicions of Money Laundering

All employees / temporary staff / contractors must immediately / as soon as practicable report any knowledge of or suspicion of (or where there are reasonable grounds to suspect) suspicious activity to the MLRO in the prescribed form as set out in this policy document.

Once the matter has been reported to the MLRO, the employees / temporary staff / contractors must follow the directions given to him / her and must NOT make any further enquiry into the matter.

The employees / temporary staff / contractors must NOT voice any suspicions to the person(s) whom they suspect of money laundering, as this may result in the commission of the offence of “tipping off”. They must NOT discuss the matter with others or note on the file that a report has been made to the MLRO in case this results in the suspect becoming aware of the situation.

6. Consideration of the Disclosure by the MLRO

Once the MLRO has received the report, it must be evaluated in a timely manner in order to determine whether:

· There is actual or suspected money laundering taking place; or

· There are reasonable grounds to know or suspect that this is the case; and

· Whether the MLRO needs to lodge a Suspicious Activity Report (SAR) with the National Crime Agency (the NCA).

Where the MLRO concludes that there are no reasonable grounds to suspect money laundering then consent will be given for any on-going or imminent transaction(s) to proceed.

Where consent is required from the NCA for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the NCA has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NCA.

All disclosure reports referred to the MLRO and reports made to the NCA will be retained by the MLRO in a confidential file kept for that purpose, for a minimum of 5 years.

The MLRO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.

7. Customer Identification and Due Diligence

Due diligence is performed on all customers who must provide basic information including full name, [residential / business] address, date of birth (individuals), registration details (corporate bodies).

Enhanced Due Diligence

It may be necessary for the Company to carry out enhanced due diligence on certain customers where the customer or a transaction involving the customer appears to be “high risk”. This means that there is a higher level of identification and verification of the customer’s identity required. The following non-exhaustive list of situations may indicate a “high risk”:

· a new customer;

· a customer not well known to the Company;

· customers in known high risk industries and/or jurisdictions;

· transactions that are unusual or appear to be unusual for that customer;

· highly complex transaction or payment arrangements;

· the transaction involves a politically exposed person (“PEP”) or an immediate family member or a close associate of a PEP;

· no face to face meetings take place with the customer where this is usually expected; and

Employees / temporary staff / contractors must assess the money laundering risk for each customer and if you suspect enhanced due diligence is required, you should speak to the MLRO before continuing any engagement with the customer. The MLRO will be required to approve the continuance of the business relationship.

If enhanced due diligence is carried out, the MLRO must:

· obtain additional information on the customer and on the customer’s beneficial owner(s);

· obtain additional information on the intended nature of the business relationship;

· obtain information on the source of funds and source of wealth of the customer and customer’s beneficial owner(s); and

· conduct enhanced monitoring of the business relationship.

This may include but is not limited to the following:

· checking the organisation website to confirm the identity of personnel, its business address and any other details;

· attending the customer at their business address;

· obtaining additional information or evidence to establish the identity of the customer and its beneficial owner(s), including checking publicly available beneficial ownership registers of legal entities such as the registers available at Companies House;

· in the case of a PEP, seek the approval of senior management and establish the source of wealth and source of funds;

· ensure that the first payment is made into a bank account in the customer’s name;

If satisfactory evidence of identity is not obtained at the outset then the business relationship or one-off transaction(s) cannot proceed any further. A report should be filed with the MLRO who will then consider if a report needs to be submitted to the NCA.

8. Ongoing Monitoring

Employees / temporary staff / contractors should review customers at regular intervals to ensure that the risk level of each customer information and information held on each customer is not only accurate and up to date but is consistent with the knowledge of the customer and its business. Further due diligence may be required if new people become involved at a customer. Any suspicious activity must be reported to the MLRO.

9. Data Protection

Customer details must be collected in accordance with the Data Protection Act 2018. This data can be “processed” as defined under the Data Protection Act 2018 to prevent money laundering and terrorist financing.

10. Record Keeping

Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 5 years from the end of any business relationship with that customer.