Legal

Privacy Policy

FREDER LTD Privacy Policy

Last updated: March 2026


Freder Ltd ("we", "us", "our") is committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Data Protection Act 2018. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in relation to it.

Please read this policy carefully. By using our website (www.freder.co.uk) or our services, you confirm that you have read and understood this policy.

1. Who We Are

Freder Ltd is a London-based property agency registered in England and Wales. We are the data controller for personal data collected through our website and services.

 

Contact details:

●      Address: 180 Strand, 2nd Floor, London WC2R 1EA

●      Email: accounts@freder.co.uk

●      Telephone: +44 (0) 2033 756 374 

2. What Personal Data We Collect

2.1 Information you provide to us

When you use our website, contact us or engage with our services — including through our AI assistant Fred — you may provide us with:

●      Your name, email address, phone number and postal address

●      Property search criteria, budget and preferences

●      Details of maintenance issues or complaints you report

●      Information provided when registering as a tenant, buyer, landlord or vendor

●      Any other information you choose to share in conversations with Fred or our team

2.2 Information we collect automatically

When you visit our website, we may automatically collect:

●      Your IP address, browser type and version

●      Pages visited, time spent on each page, and clickstream data

●      Device and operating system information

This information is collected anonymously and cannot be used to personally identify you. 

2.3 Information collected through Fred (AI Concierge)

Our website features an AI-powered chat assistant called Fred. When you interact with Fred, the content of your conversation — including any personal details you voluntarily share such as your name, contact number or property address — is processed in real time by Anthropic PBC, a US-based artificial intelligence company, solely for the purpose of generating Fred's responses.

Where you complete a workflow through Fred (such as reporting a maintenance issue, registering your details or making an enquiry), relevant personal information is transmitted to Freder Ltd by email via SendGrid, a US-based email delivery service, and retained in accordance with our standard data retention practices.

Fred does not store conversation content on Freder's servers. Conversations exist only within your browser session and are automatically deleted when you close or refresh the page.

3. Cookies

A cookie is a small file stored on your browser or device when you visit a website. We use analytics performance cookies to understand how visitors use our website. These cookies collect anonymous, aggregated data only and cannot identify you personally.

Fred does not use cookies or tracking technologies.

You can manage or delete cookies at any time by adjusting your browser settings or visiting www.allaboutcookies.org/manage-cookies/. You may also decline cookies via the cookie notice displayed at the bottom of our website.

4. How We Use Your Personal Data

We use your personal data for the following purposes: 

4.1 To provide our property services

●      To respond to your enquiries and property search requests

●      To match you with suitable properties for rent or purchase

●      To arrange viewings, valuations and property management services

●      To fulfil our obligations under any contract entered into with you 

4.2 To operate and improve our website

●      To administer and maintain our website

●      To analyse how our website is used and improve its performance

●      To ensure the security of our website and services 

4.3 To communicate with you

●      To send you property alerts matching your registered criteria

●      To notify you of changes to our services

●      To respond to maintenance reports, complaints or other requests

4.4 To operate Fred (AI Concierge)

●      To process your queries and generate relevant, accurate responses

●      To route completed workflows (such as maintenance reports or registrations) to the appropriate Freder team member by email

5. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

●      Contract: where processing is necessary to perform a contract with you or take steps at your request before entering into one

●      Legitimate interests: where we have a legitimate business interest in processing your data, such as improving our services or responding to enquiries, and that interest is not overridden by your rights

●      Consent: where you have given us clear consent, such as opting in to property alerts or marketing communications

●      Legal obligation: where processing is required to comply with a legal obligation

6. International Data Transfers

Some of our service providers are based outside the United Kingdom and European Economic Area (EEA). In particular:

 

●      Anthropic PBC (United States) — processes conversation data through Fred in real time to generate AI responses

 

Our backend server infrastructure is hosted in Western Europe, which is within the EEA.

Where personal data is transferred outside the UK or EEA, we ensure that appropriate safeguards are in place in accordance with UK GDPR and EU GDPR, including standard contractual clauses or adequacy decisions where applicable. Anthropic's data processing practices are described in their Privacy Policy at anthropic.com/privacy.

7. Disclosure of Your Information

We do not sell your personal data. We may share your information in the following limited circumstances:

 

●      With members or subsidiaries of Freder Ltd for the purposes described in this policy

●      With business partners, suppliers and sub-contractors where necessary to fulfil a contract or service request

●      With analytics and search engine providers to help us improve our website

●      With AI and technology service providers (including Anthropic and SendGrid) necessary to operate our services

●      With regulatory authorities or law enforcement agencies where required by law

 

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection law. 

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. In particular:

 

●      Fred conversation content: not retained — deleted automatically at end of browser session

●      Email records (maintenance reports, registrations, enquiries): retained for up to 7 years in line with standard business records obligations

●      Website analytics data: retained in anonymised form for up to 26 months

●      Marketing preferences: retained until you opt out or withdraw consent

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or disclosure. However, no method of transmission over the internet is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security of data transmitted to our website.

10. Your Rights

Under UK GDPR and EU GDPR, you have the following rights in relation to your personal data:

 

●      Right of access: to request a copy of the personal data we hold about you

●      Right to rectification: to request correction of inaccurate or incomplete data

●      Right to erasure: to request deletion of your personal data in certain circumstances

●      Right to restrict processing: to request that we limit how we use your data

●      Right to data portability: to receive your data in a structured, machine-readable format

●      Right to object: to object to processing based on legitimate interests or for direct marketing

●      Right to withdraw consent: where processing is based on consent, to withdraw it at any time

 

To exercise any of these rights, please contact us at accounts@freder.co.uk. We will respond within one calendar month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

11. Marketing

We will only send you marketing communications (such as property alerts or service updates) where you have opted in to receive them. You may withdraw your consent or opt out of marketing at any time by contacting us at accounts@freder.co.uk or by clicking the unsubscribe link in any marketing email.

12. Third-Party Links

Our website may contain links to third-party websites including property portals, partner services and social media platforms. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies before submitting any personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. We will post any updated policy on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the way we handle your personal data, please contact us:

 

●      Email: accounts@freder.co.uk

●      Post: Freder Ltd, 180 Strand, 2nd Floor, London WC2R 1EA

●      Telephone: +44 (0) 2033 756 374

 

For information about how Anthropic processes data when you use Fred, please refer to Anthropic's Privacy Policy at anthropic.com/privacy.

 


Anti Money Laundering

Anti Money Laundering Policy

Last updated December 2024

 

As part of the Money Laundering Regulations 2017 we have to obtain and hold identification and proof of address for all customers. The transactions that we deal with day in day are deemed as high risk for money laundering and this is why we take our Anti-Money Laundering processes seriously.

 

As part of our due diligence we have to obtain and hold identification and proof of address for all customers. We also establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place. If necessary we may also need to identify the source or destination of funds.

 

Please see below for a full list of acceptable identity documents. Please note we will require sight of all original or certified documents.

 

Individual identity documents


We require one document from List A and one document from List B.

 

List A – Identity Document
Current signed passport

 

Valid UK driving licence

 

EEA member state identity card

 

List B – Proof of address
UK/EU/EEA Drivers Licence (if UK Drivers Licence not used as ID)
Must be valid, not expired. Photo only. Full or provisional.

 

Bank, Building Society or Credit Union Statement
Dated with 3 months. Must include account number and show recent activity. No general correspondence.

 

Credit Card Statement 

Dated within 3 months. Must include account number and show recent activity. No general correspondence.

 

UK, EU, EEA Mortgage statement
Dated within 12 months. Must show account number. No general correspondence.

 

Utility Bill
Dated within 6 months E.g. Gas, electricity, water. Must show address for service and/or account number. No general correspondence.

 

Telephone Bill
Dated within 6 months E.g. Landline or mobile pay monthly (excluding pay as you go). Must show address for service and/or account number. No general correspondence.

 

Council Tax
Dated within 12 months. Must show address for service and/or account number. No general correspondence.

 

Tenancy Agreement
Dated with 12 months. Must state full name and full property address. Issued by local council, housing association, solicitor or reputable letting agent.

 

Benefits Entitlement Letter
Dated within 12 months. Issued by DWP or Jobcentre plus. Must confirm benefit payable at time of issue. E.g. Pension, disability, single parent, housing etc.

 

HMRC Tax Notification
Dated with 6 months. Must state national insurance number and tax calculation. No general correspondence.

 

Home or Motor Insurance Certificate
Dated within 12 months. Must state insured address or registered address for vehicle and policy number. No general correspondence.

 

UK solicitors letter confirming house purchase/land registration
Dated with 3 months. Must state full name of new proprietor and full property address.

 

NHS Medical Card or letter from GP confirming registration
Dated within 3 months. Must state individual’s date of birth and NHS number. No general correspondence.

 

Official confirmation of Electoral Register entry or official poll card
Dated within 12 months. Must state full name and full address. No general correspondence.

 

Police Registration Certificate
Dated within 12 months. Must state the full residential address of the individual.

 

Probate

 

If you are acting as a Representative of an Estate we require the following:

  • Grant of Probate (if a will was left)
  • Letter of administration (if no will left)
  • Individual identity evidence from List A & B for the Personal
  • Representative, either executor or administrator

Limited company

 

If you are acting as a Representative of a UK Company we will also require the following:

  • Certificate of Incorporation
  • Articles of Association
  • Memorandum of Association
  • Latest Annual Return or Confirmation Statement, with details of current company officers
  • If offshore, nominee director declaration and a general power of attorney
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

If you are acting as a Representative of an Offshore Company we will also require the following:

  • Certificate of Incorporation
  • Articles of Association, Memorandum of Association, Latest
  • Annual Return with details of current company officers, Share
  • Certificate(s) showing the Ultimate Beneficial Owner OR
  • Certificate of Incumbency
  • If the shares are owned by another company, repeat steps above for the holding company
  • Nominee director declaration and/or general Power of Attorney (if applicable)
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

Trust

If you are acting as a Representative of a Trust we require the following:

  • Trust deed
  • List of trustees
  • List of beneficiaries
  • Individual Identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the Trust

Client Money Handling

1. Client Account policy


Freder Ltd Client Account is operated in the United Kingdom.

Client money is money that a registered organisation receives and holds for its

clients. It can include, but is not limited to, payments made by a client in advance of

agreed work being completed by the registered organisation or payments made for

unpaid disbursements.

 

The purpose of a client account is to protect client money and prevent it from being

mixed with monies related to the registered organisation’s general business

activities.

 

A Client account is not necessary if the registered organisation invoices clients only

after the work is completed and arranged for clients to make any necessary

payments direct to the Home Office or other authorities.

 

2. The client account of:


Freder Ltd policy related to the operation of this account.

Company directors are responsibility for the account and how withdrawals and

transfers from the client account are made. Accounts department and administrators

have access to register expenses and set up payment to clients within a

password protected IT system but only directors can approve and make payments

from the client account.

 

This policy might additionally include the following:

 

 The account’s purpose; is to separate client money with company expenses.

 

 The bank details:

 

Bank: HSBC

Account Name: Freder Ltd Client Account

Account No: 13000192

Sort Code: 40-06-41

IBAN: GB37HBUK40064113000192

BIC: HBUKGB4B


 Payments into the client account are made upon receiving a tenant statement

or expense invoice detailing what the monies is being requested for.

 

 Withdrawal and transfers from the client account are made when

a landlord statement is due or when a property expense or bill is due to the

client.

 

 The accounting records for the client account is stored with in a

3rd party password protected IT system with fully transparent audit trail

history available to view for each user.

 

 Reconciliations and errors in the account will be addressed on an

annual basis and any adjustment will be communicated in writing.

Freder Ltd pays client money received by the into their client account without delay.

Only company directors can approve payment going out of the client

account, accounts and administrators can set up expenses upload documents for

accounts to set up payment and only directors to approve payments.

Money held in a client account be immediately available to the client on demand.

 

Our client account must not become overdrawn at any time.

 

Any interest on a client account belongs to the client and not the registered

organisations.

 

Freder Ltd will solely use money in the client account for business purposes.

Payments into, and transfers or withdrawals from, a client account must be in

respect of instructions relating to a transaction or to service forming part of the

registered organisation’s normal registered activities.

 

3. Use of the client account


Further to Code 26(e) and Code 64, if a client pays money into Freder Ltd client

account in advance of work to be done, that such money remains the clients and will

be deposited into the client account.

 

If the fee is paid into the client account, Freder Ltd will inform the client when the

agreed work has been completed and that they will be using money in the client

account to pay the fee for that work. This is done by sending the client a written

invoice stating what work has been done.

 

After the invoice has been issued the relevant fee is transferred into the business

bank account. It is no longer client money.

 

If, at the conclusion of the client’s matter, there are any surplus funds remaining in

the client account, those funds (including any interest accrued) this will be promptly

returned to the client.

 

4. Withdrawals from a client account


There is no option to withdraw physical cash from the client account and only

internal transfers or payment authorisations can be made by

following company procedures and by directors’ approval before any monies can

leave the account.

 

Client money may only be withdrawn from a client account when it is:

 

a) properly required for a payment to, or on behalf of, the client.

b) properly required for payment of a disbursement on behalf of the client (see

below).

c) properly required in full or partial reimbursement of money spent by the

organisation on the client’s behalf.

d) transferred to another client account within the same organisation if appropriate

and agreed in writing by the clients involved

e) withdrawn on the client’s instructions provided that these instructions are in

writing; and

f) money which has been paid into an account in breach of the Code. Such money

must be promptly withdrawn upon discovery

 

Money held for a client in a separate designated client account must not be used for

payments for another client unless (d) above is satisfied.

Money withdrawn from a client account, which is required for payment for work

completed, must only be paid directly into the registered organisations business

account.

 

Disbursements are generally expenses that a registered organisation must pay on

behalf of a client for services provided to the client or on the client’s behalf. These

are payments that may be made from the client account.

 

Examples of disbursements might include office fees (such as special postage/

courier) or travel and accommodation costs, where such costs are not already

included in the agreed client fee for the work to be undertaken.

 

As an alternative to clients paying fees to registered organisations that will

subsequently need to be passed to authorities, clients should be encouraged to pay

fees directly to the authorities. The Commissioner recognised that there may be

exceptional instances where this is not possible, for example where the client does

not have a bank account and in such circumstances these fees may be paid into the

client account.

 

Organisations may be found to be in breach of Code 61 as overcharging the client

where, for example, the standards of advice and service fall below what could

reasonably be expected to have been delivered given the agreed instruction, or

where the work agreed to be undertaken is not delivered because of a fault of the

registered organisation.

 

If a registered organisation charges a fee at an hourly rate, they must maintain and

retain detailed and accurate records evidencing the work completed and the time

taken to justify the fee charged.

 

Freder Ltd operate in a transparency in all dealings with clients’ monies.

 

Freder Ltd Incorporated in England and Wales Company Number 11945314

Member of Client Money Protect

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