Longrad AML Privacy

Who we are

Longrad Ltd ("Longrad", "we") is an estate and letting agency supervised by HM Revenue & Customs (HMRC) under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLRs"). We are the controller of the personal data described in this statement.

Longrad Ltd, 23 Berkeley Square, London W1J 6HE, United Kingdom · info@longrad.com · +44 (0)208123 7983 · ICO registration no. ZA123757 · Data protection contact: Roman Grigoriev / Director, roman@longrad.com

2. Why we collect your data

Before we can act on a sale, purchase or letting, the law requires us to carry out customer due diligence on our customers and the other party to the transaction. This applies to the individuals who own, control or act for a company, trust or other organisation. We use the personal data collected for these checks only to prevent money laundering, terrorist financing and proliferation financing, unless another law allows a different use or you consent to it.

3. What data we collect

Identity: full name, former names, date and place of birth, nationality, photograph, copies of passports, identity cards or driving licences, and results of electronic identity checks (including a facial-likeness and liveness check where an online identity check is used);
Contact and address: residential address, proof of address, telephone number, email address Company and ownership: roles as director, shareholder, beneficial owner or signatory;
company registers, constitutional documents and ownership structure charts
Financial: source of funds and, where required, source of wealth, including bank statements, company accounts and declarations;
Screening: results of checks against sanctions lists, politically exposed person (PEP) databases and adverse media, which may include information about alleged or proven offences;
Transaction: the property, the price or rent, the parties, and our records of the checks and decisions.

We collect this data from you, from people acting for you, and from public and commercial sources such as Companies House and overseas company registers, HM Land Registry, sanctions lists, credit reference and identity verification providers, and public internet sources. Some of this information comes from the credit reference agency Experian, via our screening provider. How Experian uses personal data is explained in its Credit Reference Agency Information Notice:
https://www.experian.co.uk/crain/.

4. Our legal basis

Processing personal data under the MLRs is necessary for the prevention of money laundering, terrorist financing and proliferation financing. It is treated as necessary for the performance of a task carried out in the public interest (UK GDPR Article 6(1)(e)) and to comply with our legal obligations (Article 6(1)(c)).

Where screening reveals information about criminal offences, we process it only as permitted by the Data Protection Act 2018 [condition, e.g. Schedule 1: regulatory requirements / preventing or detecting unlawful acts].

Providing this data is a statutory requirement. If you do not provide it, we cannot act on, or continue with, the transaction.

5. Who receives your data

We share your data only as far as needed for the purposes above.

Recipient	Role	Purpose
Google Cloud EMEA Limited (Google Workspace)	Processor	We store and process your case file using Google Drive and other Google Workspace services (Gmail, Google Docs, Google Sheets, Google Calendar).
Anthropic, PBC	Processor	We use Claude, a business AI assistant, to help our staff organise case files, prepare checklists and draft correspondence. Anthropic processes this data only on our instructions and under a data processing agreement, and does not use it to train its models.
Creditsafe	Independent controller	Electronic identity verification, sanctions, PEP, adverse media and company data checks. Creditsafe uses data from its own providers, including the credit reference agency Experian.
The other party's agent, the landlord or seller, solicitors or conveyancers	Independent controller	Only where necessary for the transaction or where another regulated firm relies on our checks, as the MLRs allow.
HMRC, the National Crime Agency, the Office of Financial Sanctions Implementation, police and other authorities	Independent controller	Where the law requires or permits us to share information.
Our professional advisers and auditors	Independent controllers / processors	Legal, compliance and audit purposes.

All decisions about your checks are made by our staff. The tools above, including our AI assistant, help us prepare and organise the work. They do not decide whether we act for you, and everything they
produce is reviewed by a member of our team.

6. Transfers outside the UK

To meet our obligations under the UK Money Laundering Regulations, we use electronic identity verification and screening providers, and cloud services including Google Workspace (Google Drive and other Google services) and Anthropic, PBC, to store and process your data. As a result, your personal data may be transferred to, stored or processed outside the United Kingdom. Whenever this happens, we make sure it receives a similar degree of protection by ensuring that at least one of the
following safeguards applies:

Adequacy: the country or framework has been found by the UK Government to provide an adequate level of protection for personal data. This includes transfers to US organisations certified under the UK Extension to the EU–US Data Privacy Framework.
Approved contract terms: where a provider or its sub-processor is in a country without adequacy, we rely on approved contractual safeguards, namely the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum, with appropriate technical and security measures such as encryption.

You can ask us for a copy of the relevant safeguards.

7. How long we keep your data

We keep due diligence records for 5 years from the end of our business relationship with you, or from the date of the transaction. This also applies where a transaction does not go ahead: the law requires us to keep the records of the checks we carried out. This is the period required by the Money Laundering Regulations 2017 (regulation 40). After that we delete them, unless we must keep them for legal proceedings, a statutory requirement or with your consent.

8. Automated decision-making

We do not make decisions about you based solely on automated processing. We use an AI assistant to help organise documents and prepare internal notes, but it does not make decisions about you.
Electronic identity and screening checks are reviewed by a member of our compliance team.

9. Your rights

You have the right to:

access your personal data
have inaccurate data corrected
ask for your data to be erased or its processing restricted
object to processing
data portability, where it applies

Some rights are limited where we must keep records under the MLRs, or where disclosure could prejudice the prevention or detection of crime. To exercise a right, contact Roman Grigoriev, Director, roman@longrad.com.

10. Complaints

You can complain to the Information Commissioner's Office (ICO), www.ico.org.uk, telephone 0303 123 1113. We would welcome the chance to deal with your concern first.

11. Changes

We will update this statement when our processing changes. Version 1.3. 03 November 2026

© 2026 Longrad LTD, incorporated and registered in England and Wales, registered number: 8560970.

Registered office: 23 Berkeley Square, Mayfair, London, W1J 6HE.

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