Last updated: 7 August 2026     |     Version: 1.0

This Privacy Policy explains how Charlecote Residential Ltd handles your personal data — both as the operator of the Century 21 Fine Homes & Estates website and as an estate agency providing services directly under the Century 21 Fine Homes & Estates name. It does not cover the separate processing carried out by other independent Century 21 offices, each of which has its own privacy policy.

1. Who we are

This Privacy Policy explains how Charlecote Residential Ltd (“we”, “us”, “our”) collects, uses, shares and protects your personal information when you visit or submit an enquiry through the Century 21 Fine Homes & Estates website, when you use the estate agency services we provide directly, or when you otherwise contact us.

Charlecote Residential Ltd is the data controller responsible for the personal data processed through the Century 21 Fine Homes & Estates website and for the estate agency services we provide directly.

• Registered company name: Charlecote Residential Ltd
• Company number: 16540147
• Registered address: 32B Staple Gardens, Charlecote Mews, Winchester, SO23 8SR
• ICO registration number: ZB926571 (you can verify this on the ICO’s public register)
• Anti-money-laundering supervision: HM Revenue & Customs (HMRC), registration number XPML00000214051
• Property redress scheme: The Property Ombudsman
• Client Money Protection: provided through RICS (Royal Institution of Chartered Surveyors)
• Data Protection Officer: Sam Molyneux-Summers, compliance@century21uk.com

How Century 21 Fine Homes & Estates works

Charlecote Residential Ltd has two roles, and this policy covers both.

As operator of the website and as franchisor, we run the Century 21 Fine Homes & Estates brand and website. Century 21 Fine Homes & Estates is a franchise network, and a local office may be independently owned and operated by a separate legal entity (a “franchisee”). When you submit an enquiry that relates to an area or property served by one of those independent offices, we collect your details and pass them to that office so they can help you. From that point, that office handles your property matter as a separate, independent data controller — registered separately with the ICO and, because it carries out estate agency work, with HMRC for anti-money-laundering purposes — with its own Data Protection Officer and its own privacy policy.

As an estate agency in our own right, we also provide estate agency and related property services directly, trading under the Century 21 Fine Homes & Estates name. Where we deal with your property matter ourselves, we are the data controller for that service and carry out the full range of processing described in this policy — including the identity and anti-money-laundering checks we are legally required to perform. We are supervised by HM Revenue & Customs (HMRC) for anti-money-laundering purposes.

In short: if we pass your enquiry to a separate local office, that office is the controller for what happens next; where we act for you directly, we are the controller. If you are unsure which applies to you, contact us using the details in Section 1.

2. The information we collect

2.1 Information you give us

When you enquire through our website or contact us, we may collect:

• Your name and contact details (email, phone, postal address)
• The property or area you are interested in, and your requirements or preferences
• The content of your enquiry and any information you choose to include in it
• Records of our communications with you

If you go on to instruct us, or we act for you in a property transaction, we also collect:

• Proof of identity and address (for example passport or driving licence, and a recent utility bill or similar)
• Proof and source of funds, and financial information relevant to the transaction
• Details of the property, your offer and negotiations, and the progress of the sale, purchase or letting
• Information needed for our identity, anti-money-laundering, sanctions and politically-exposed-person (PEP) checks

If you are a landlord or tenant, we may also collect:

• References and referencing-check results (for example credit, employment and previous-landlord references), and guarantor details where applicable
• Tenancy, rent and deposit information, and — for properties we manage — maintenance, access and contractor details

Where your matter is handled by a separate local franchise office, that office carries out its own identity and anti-money-laundering checks. Where we act for you directly, we carry out those checks ourselves, because the law requires us to (see Section 3).

2.2 Special category and criminal offence data

We do not routinely collect special category data (such as health information) through the website. If you include such information in an enquiry, or share it with us during a transaction, we use it only so far as needed to assist you.

When we carry out anti-money-laundering, sanctions and PEP checks, we may process information relating to actual or alleged criminal offences. We do this only to meet our legal obligations.

2.3 Information we collect automatically

When you visit our website we may collect your IP address, browser type, device and operating system information, and details of how you use the site (pages visited, dates and times). See Section 8 (Cookies).

2.4 Information we receive from others

We may receive information about you from third parties, including property portals (for example Rightmove, Zoopla), our franchise offices, identity and anti-money-laundering verification providers, sanctions/PEP screening and anti-fraud agencies, tenant referencing and credit-check agencies, and other people involved in your transaction (such as solicitors or mortgage brokers), where relevant to your enquiry or matter.

3. How we use your information, and our lawful basis

Under UK data protection law we must have a valid “lawful basis” for using your personal data. The table below sets out how we (Charlecote Residential Ltd) use your data.

Where we rely on consent (for example for marketing), you can withdraw it at any time (see Section 7). Where we pass your enquiry to a separate franchise office, that office decides how it uses your data and on what lawful basis, and will tell you in its own privacy policy.

4. When we share your information

We do not sell your personal data. We share it only where necessary, with:

• The relevant Century 21 franchise office — where we route your enquiry to a separate local office. Once passed on, that office holds your data as a separate, independent data controller.
• Other people involved in your transaction — for example solicitors and conveyancers, mortgage brokers and lenders, surveyors and other agents — where needed to progress your matter.
• Referencing and credit-check agencies, where we reference a prospective tenant or guarantor.
• Identity, anti-money-laundering, sanctions/PEP screening and anti-fraud providers we use to meet our legal obligations.
• The Tenancy Deposit Scheme, where we hold a tenancy deposit, together with the information the scheme requires.
• Contractors and tradespeople, for properties we manage, to arrange repairs, maintenance and inspections.
• HMRC, the ICO, our redress scheme (The Property Ombudsman), law enforcement and other regulators or public bodies — where we are legally required to disclose, including submitting suspicious activity reports (which the law may prevent us from telling you about).
• Our service providers who help us operate the website and business — for example IT, hosting, CRM and marketing providers, who act on our instructions.
• A buyer of our business or assets in the event of a sale, merger or restructuring.

We require our service providers to protect your data and to use it only for the purposes we specify.

Deposits and client money

Where we hold a tenancy deposit, we protect it with the Tenancy Deposit Scheme and give you the prescribed information about that protection. Any client money we handle is protected under a Client Money Protection scheme provided through RICS (the Royal Institution of Chartered Surveyors).

5. Where we store and process your data

We store and process your personal data within the UK. We do not transfer your personal data outside the UK. If this changes in the future, we will update this policy and make sure any transfer is protected by an appropriate safeguard recognised under UK data protection law.

6. How long we keep your information

We keep your personal data only for as long as necessary for the purposes we collected it:

• Website enquiry and lead data (details you submit and that we pass to a franchise office): we keep this for 5 years. Because we handle complaints about franchise offices, we retain these records so we can properly investigate and respond to any complaint that may arise.
• Client, transaction and anti-money-laundering records (where we act for you directly): we keep these for 5 years after the end of our business relationship or the completion of the transaction, as required by the Money Laundering Regulations 2017, after which we securely delete or anonymise them.
• Tenancy and property-management records (where we act in a lettings or management capacity): kept for the duration of the tenancy or management arrangement and for a reasonable period afterwards to meet our legal, tax and regulatory obligations.
• Marketing data: kept until you unsubscribe or ask us to stop, and reviewed periodically.
• Website / analytics data: kept no longer than necessary and reviewed regularly.

Where your matter is handled by a separate franchise office, that office holds and retains your data as a separate controller under its own policy.

7. Your rights

Under UK data protection law you have the right to:

• Be informed about how we use your data (this policy)
• Access the personal data we hold about you (a “subject access request”)
• Rectification — have inaccurate data corrected
• Erasure — have your data deleted in certain circumstances
• Restrict our processing of your data in certain circumstances
• Data portability — receive your data in a structured, commonly used, machine-readable format
• Object to processing based on our legitimate interests, and to direct marketing at any time
• Rights relating to automated decision-making — we do not make decisions about you based solely on automated processing without human involvement
• Withdraw consent at any time where we rely on your consent

Some of these rights are limited where we are required to keep information to meet a legal obligation — for example, we must retain anti-money-laundering records even if you ask us to erase them.

To exercise any of these rights in respect of the data we hold, contact us using the details in Section 1. If your enquiry has been passed to a separate local franchise office, you may also need to contact that office directly, as it is a separate controller for the data it holds. We will normally respond within one month, and may ask you to verify your identity first.

Complaints

If you are unhappy with how we have handled your personal data, please contact us first using the details in Section 1 — we take complaints seriously, will acknowledge yours promptly and aim to resolve it fairly.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at any time:

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We would, however, appreciate the chance to address your concerns before you approach the ICO.

8. Cookies and similar technologies

Our website uses cookies and similar technologies. When you first visit our site, a cookie banner lets you accept or reject non-essential cookies, and you can change your choice at any time. The cookies we use fall into the following categories:

• Strictly necessary cookies — required for the site to function. These do not require your consent.
• Statistical / analytics cookies — used solely to understand how visitors use our own site. We do not use them to track you across other sites, and you can opt out at any time.
• Functional / appearance cookies — remember your preferences and how the site is displayed to you. You can opt out at any time.
• Marketing / advertising cookies — used to show you relevant advertising. We only set these with your consent, which you can give or withdraw at any time.

You can also manage cookies through your browser settings. Blocking some cookies may affect how the site works.

9. How we protect your information

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or disclosure. No method of transmission or storage is completely secure, but we work to keep our systems and processes up to date.

10. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. We will post the updated version on our website and update the “Last updated” date above. Where changes are significant, we will take reasonable steps to bring them to your attention.

11. Contact us

For any question, request or complaint about the personal data we process, please contact our Data Protection Officer:

Sam Molyneux-Summers, Data Protection Officer

Charlecote Residential Ltd

32B Staple Gardens, Charlecote Mews, Winchester, SO23 8SR

compliance@century21uk.com

If your matter is being handled by a separate local Century 21 office, that office is a separate data controller with its own Data Protection Officer — please refer to that office’s own privacy policy and contact details for data it holds.