Privacy Policy

1. Data Controller

The data controller responsible for personal data processed through the Whisper Property website is:

Dream Generator LtdRegistered office: 3rd Floor 207 Regent Street, London, United Kingdom, W1B 3HHCompany number: 12077525Country of incorporation: United KingdomPrivacy contact email: info@dreamgenerator.co.ukWebsite: whisperproperty.com

Whisper Property is a brand exclusively owned by Dream Generator Ltd and is not a separate legal entity or separate data controller.

2. Personal Data We May Collect

Depending on how you use the website or communicate with us, we may collect:

• identity and contact information, such as your name, email address, telephone number, city, country, company or organisation;
• information contained in enquiries, correspondence and messages submitted to us;
• professional, investor or business information relevant to an acquisition requirement, property, investment, advisory, mandate or professional introduction;
• information supplied when defining acquisition criteria, including investor type, investment range, property interests and other requirements voluntarily provided;
• information supplied by property owners or their representatives when submitting an asset for preliminary consideration;
• subscription preferences where you choose to receive the Whisper Property Private Dispatch or other communications;
• technical and usage information generated when you use the website, such as IP address, browser/device information, security logs and, where permitted, analytics information;
• cookie and consent preferences; and
• information that you voluntarily provide in subsequent communications with us.

Please do not submit confidential transaction documents, special-category personal data or highly sensitive information through an initial public website form unless we have specifically asked you to do so through an appropriate secure channel.

3. How We Collect Personal Data

We may collect personal data directly from you when you submit a form, request access, define acquisition criteria, enquire about an opportunity, submit a property, join the Private Dispatch, contact us by email or otherwise communicate with Whisper Property or Dream Generator.

We may also receive business contact information from professional counterparties, public professional sources, corporate websites, business directories or other lawful sources in the course of our advisory, property-sourcing and relationship-development activities. If personal data is obtained from a source other than the individual, we will provide the information required by applicable data protection law where and when required.

4. Purposes and Lawful Bases

We process personal data only where we have an appropriate lawful basis. Depending on the circumstances, processing may be necessary for the following purposes:

• responding to enquiries and taking steps requested before entering into a business relationship — legitimate interests and/or steps prior to entering into a contract;
• assessing acquisition criteria, investor requirements, property submissions and opportunity enquiries — legitimate interests and/or steps prior to entering into a contract;
• providing and administering property sourcing, advisory, representation or related services where separately agreed — performance of a contract and legitimate interests;
• identifying relevant opportunities and counterparties within our professional network — legitimate interests, subject to appropriate confidentiality and data-protection safeguards;
• maintaining business and professional relationships and communicating with relevant counterparties — legitimate interests, subject to applicable direct-marketing rules;
• sending the Whisper Property Private Dispatch or other electronic communications where consent is required — consent;
• operating, securing, maintaining and improving the website — legitimate interests and, where applicable, consent for non-essential storage/access technologies;
• meeting legal, regulatory, accounting, compliance or law-enforcement obligations — legal obligation and/or legitimate interests; and
• establishing, exercising or defending legal claims — legitimate interests and other applicable legal bases.

Where we rely on legitimate interests, we consider whether our interests are proportionate and whether your rights and interests require additional protection.

5. Private Dispatch and Direct Communications

If you join the Whisper Property Private Dispatch, we will use the information you provide to send selected perspectives, market intelligence and occasional opportunities from the private property market. Where consent is the applicable lawful basis, you may withdraw it at any time by using the unsubscribe mechanism provided in the communication or by contacting us.

6. Enquiry, Access, Investor and Property Forms

Information submitted through the website’s forms will be used to review and respond to the relevant request, route it internally where appropriate, assess relevance and qualification, maintain related correspondence and, where a relationship develops, administer that relationship.

Submitting an enquiry, acquisition requirement or property for preliminary consideration does not by itself create a mandate, agency, representation, brokerage or advisory relationship. Any formal engagement is subject to separate written terms.

7. Controlled Disclosure and Off-Market Opportunities

Whisper Property operates in a market in which certain property and investment information may be confidential, restricted or disclosed progressively. Personal data connected with an access request or opportunity enquiry may therefore be used to assess whether further disclosure is appropriate. No confidential information is released solely because a public website form has been submitted.

8. Sharing Personal Data

We do not sell personal data. We may disclose personal data where reasonably necessary to:

• website hosting, IT, email, security, analytics, communications, professional or other service providers acting under appropriate contractual arrangements;
• professional advisers, consultants, property owners, investors, counterparties or specialist partners where this is necessary for an enquiry, mandate or transaction and disclosure is lawful, proportionate and appropriate;
• other brands or business activities operated by Dream Generator Ltd where relevant to the enquiry and permitted by law;
• courts, regulators, public authorities or law-enforcement bodies where disclosure is required or legally justified; or
• a purchaser, successor or adviser in connection with a genuine corporate restructuring, merger, acquisition or transfer of business assets, subject to appropriate safeguards.

Where another professional or organisation acts as an independent controller, it is responsible for its own processing of personal data.

9. International Transfers

Dream Generator operates in an international business environment. Personal data may therefore be accessed or processed outside the United Kingdom and, where applicable, outside the European Economic Area. Where applicable law requires safeguards for an international transfer, we will use an appropriate lawful transfer mechanism, such as an adequacy regulation or decision, the UK International Data Transfer Agreement or UK Addendum, EU Standard Contractual Clauses where relevant, or another legally recognised safeguard.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to manage enquiries, access requests and business relationships and to satisfy legal, accounting, regulatory, compliance and dispute-resolution requirements.

Retention periods depend on the nature of the information and relationship. Enquiries that do not develop into an ongoing business relationship should be reviewed periodically and deleted or anonymised when there is no longer a legitimate reason to retain them. Contractual and transaction records may be retained for longer periods where required for legal or compliance purposes.

11. Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. No internet transmission or storage system can be guaranteed to be completely secure, and users should avoid sending highly sensitive information through ordinary website forms or email.

12. Your Data Protection Rights

Depending on the applicable law and circumstances, you may have rights to:

• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request erasure of personal data;
• request restriction of processing;
• object to processing based on legitimate interests or to direct marketing;
• receive certain personal data in a portable format;
• withdraw consent at any time where processing is based on consent; and
• raise a complaint with the relevant supervisory authority.

These rights are subject to legal conditions and exemptions. To exercise a right, contact us at info@dreamgenerator.co.uk. We may need to verify your identity before acting on a request.

13. Complaints and Supervisory Authorities

If you have concerns about our use of personal data, please contact us first so that we can consider the matter. Individuals in the United Kingdom also have the right to complain to the Information Commissioner’s Office (ICO). Individuals in the EEA may have the right to complain to the competent data protection authority in their country of residence, work or the place of the alleged infringement.

14. Cookies and Similar Technologies

The website may use cookies and other storage or access technologies. Strictly necessary technologies may be used without optional consent where the law permits. Non-essential technologies must not be activated before the required consent has been obtained. For further information, see our Cookie Policy and the Cookie Preferences interface available on the website.

15. Third-Party Websites

The website may contain links to other websites, including websites within the wider Dream Generator ecosystem. Those websites may have their own controllers, terms and privacy practices. Dream Generator is not responsible for the privacy practices of an independently operated third-party website.

16. Children

This website and Whisper Property’s services are directed to adult business, property and investment audiences and are not intended for children. We do not knowingly seek to collect personal data from children through this website.

17. Automated Decision-Making

We do not intend to use personal data collected through the public website to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals. Technology may assist with organisation, search, the identification of relevant opportunities or prioritisation, but material relationship and disclosure decisions remain subject to human judgement.

18. Changes to This Privacy Policy

We may update this Privacy Policy when our website, processing activities, service providers or legal obligations change. The current version will display its effective date. Material changes will be communicated where required by law.

18A. Privacy Information at the Point of Collection

When personal data is collected directly through a Whisper Property form, access workflow or account-registration process, a concise privacy notice and a clear link to this Privacy Policy may be presented at the point of collection. Where the website asks a user to acknowledge that they have read this Privacy Policy, that acknowledgement is intended to evidence provision of privacy information and is not, by itself, relied upon as consent where another lawful basis applies.

18B. Form Notifications and Internal Routing

Information submitted through acquisition-criteria, access, enquiry, property-owner, private-conversation, transaction-stage and related forms may be recorded in the website's secure systems and routed by operational email notification to authorised personnel of Dream Generator Ltd so that the relevant request can be reviewed and managed. Operational notifications are part of the administration of the user's request and are not marketing communications. Passwords, authentication tokens, signed access links and other security secrets should not be included in such notifications.

18C. Marketing Choices and Consent Records

Where consent is relied upon for the Whisper Property Private Dispatch or other electronic direct marketing, the marketing choice must be presented separately from service, access or enquiry requirements and must require a clear affirmative action. Marketing consent is not a condition of submitting an acquisition criterion, requesting access, making an enquiry or using another core website function. Where consent is relied upon, we may retain appropriate evidence of who consented, when and how, what they were told, the relevant privacy or consent wording/version, and any subsequent withdrawal.