Privacy & Cookies Policy

Effective date: 14 July 2026

Introduction ROC Invest (“we”, “us”, “our”) is a discreet, boutique property house sourcing off‑market opportunities across London and the UK for high net worth clients, family offices and overseas investors. This Privacy & Cookies Policy explains how we collect, use, disclose and protect personal data through our website and related services, and how we use cookies and similar technologies. It also describes your rights and how to exercise them.

This policy applies to personal data we process in connection with our website, enquiries, marketing activities and provision of services. For specific terms governing a transaction or engagement, separate contractual terms and privacy notices may apply.

Controller ROC Invest is the data controller for personal data processed in connection with this website and our services. Our registered contact details are available on the website.

Data we collect We collect and process personal data necessary to provide our services, communicate with you and meet legal and regulatory obligations. Categories of personal data may include:

• Identity and contact information: name, job title, company, email address, telephone number, postal address.

• Transactional and engagement information: details of property interests, project specifications, financial preferences, investor mandates, correspondence, meeting notes.

• Business and professional information: company details, professional background, intermediary or advisor details.

• Technical and usage data: IP address, browser and device type, operating system, pages visited, referral source, date/time of access, cookies and similar technologies.

• Communications: records of enquiries, emails, calls and meeting notes (where consent has been provided or legitimate interest applies).

• Sensitive data: in limited circumstances we may process special category data (such as nationality or immigration status) where necessary for compliance, or where you have provided it with explicit consent. We will only process special category data where we have a lawful basis and appropriate safeguards.

Lawful bases for processing We rely on the following lawful bases under UK data protection law to process personal data:

• Performance of a contract: to provide property sourcing and related services where you are a client or have engaged us.

• Legitimate interests: to operate and improve our business, manage relationships, profile property interests to match opportunities, fraud prevention, network and business development, and to communicate with prospective clients and vendors where such communications are expected.

• Legal compliance: to comply with legal and regulatory obligations, including anti‑money laundering, tax and record‑keeping requirements.

• Consent: where we ask for and obtain your explicit consent for specific processing (for example direct marketing by email where required). You can withdraw consent at any time.

How we use personal data We use personal data for purposes including, but not limited to:

• Responding to enquiries and providing information about our services.

• Sourcing, marketing and negotiating property opportunities on behalf of clients and vendors.

• Matching investors with off‑market opportunities and presenting opportunities to potential purchasers.

• Performing contractual obligations and administering client relationships.

• Verifying identity and conducting due diligence (including anti‑money laundering checks).

• Communicating updates, newsletters or market information where lawful and appropriate.

• Improving our website, services and business operations.

• Protecting our legitimate interests, enforcing our rights and defending claims.

• Complying with legal and regulatory obligations.

Sharing and disclosing personal data We may share personal data with:

• Service providers and professional advisers engaged to support our business (e.g. IT, CRM providers, legal, accounting, compliance, property consultants). These parties act as processors or independent controllers and are required to protect personal data.

• Third parties involved in a transaction: buyers, sellers, agents, surveyors, brokers, lenders, solicitors, tax advisers and other parties necessary to progress a transaction or engagement.

• Public and regulatory bodies: where required by law, regulation or court order, including for anti‑money laundering, tax reporting and law enforcement requests.

• Acquirers: in the event of a sale, merger or reorganisation of our business we may transfer personal data to a prospective purchaser or successor who will be bound by confidentiality and data protection obligations.

• Other recipients with your consent.

International transfers Personal data may be transferred to, and stored or processed in, countries outside the UK. Where transfers occur we will ensure appropriate safeguards are in place, such as the use of UK adequacy decisions, standard contractual clauses, or other mechanisms permitted by law to ensure an adequate level of protection.

Data retention We retain personal data for as long as necessary for the purposes for which it was collected, to fulfil contractual and legal obligations, to resolve disputes, and to meet legitimate business needs. Retention periods vary by data type and purpose; for example, client records and transaction documentation are kept in line with regulatory and tax retention requirements. When data is no longer required it will be securely deleted or anonymised.

ROC Invest is a trading name for ROC Residential Ltd.

ROC Residential Ltd is registered in Accountancy House, 90 Walworth Road, London, SE1 6SW Registration number: 12729182.

ROC Invest Ltd: Company number 06819867, 20 Seymour Mews, London, United Kingdom, W1H 6BQ