Privacy Policy

Last updated: 22 May 2026

This Privacy Policy explains how Apaqco Ltd, trading as SurveyorNotes.uk and Surveyor.Directory ("we", "us", "our"), collects, uses, and protects personal data when you use our websites and services at surveyornotes.uk and surveyor.directory (together, the "Service"). It applies to both sites.

We are committed to processing personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection law.

1. Who we are (Data Controller)

Apaqco Ltd is the data controller for the personal data described in this policy.

• Registered company: Apaqco Ltd (registered in England and Wales, company number 07872761)
• Address: TAP, 70 Grange Road, East Wirral, CH41 5FE
• Contact for data protection matters: [email protected]

We act as a data controller in these respects:

1. For your account and customer data — the personal data you give us when you register, subscribe, and use the Service.
2. For the property and public-register data we aggregate — including data that may relate to identifiable individuals (for example, the owner or occupier of a residential property). See Section 5.
3. For the directory listings and reviews on Surveyor.Directory — including data relating to surveying firms and professionals, and reviews submitted by members of the public. See Section 6.

We decide the purposes and means of all of the above and are therefore the controller for it.

2. The personal data we collect about you (our users)

3. How we use your data and our lawful basis

Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights and freedoms. You can ask us for details of that assessment using the contact details above.

4. Cookies and analytics

We use cookies and similar technologies for essential site functionality, to remember your preferences, and to understand how the Service is used. You can control non-essential cookies through our cookie banner and your browser settings. See our [Cookie Policy / cookie settings] for details.

5. Property and public-register data we process

A core function of the Service is to aggregate and present UK property information. Some of this information is personal data because it relates to an identifiable individual — for example, the owner or occupier of a residential dwelling identified by its address.

5.1 Sources we obtain data from

We obtain property and related data from public registers and third-party providers, including:

• Energy Performance Certificate (EPC) data — from the Department for Levelling Up, Housing & Communities / Ministry of Housing, Communities & Local Government open-data service (including the Get energy performance of buildings data service).
• HM Land Registry — including Price Paid Data and related title information.
• Local authority planning portals — planning application records.
• Environment Agency — flood-risk information.
• Valuation Office Agency (VOA) — council tax band information.
• Address and geolocation providers — for address lookup and mapping (e.g. address data providers, mapping services).

5.2 Categories of property-related personal data

Depending on the source, this may include: property address and postcode, Unique Property Reference Number (UPRN), tenure (e.g. owner-occupied or rented), assessment and lodgement dates, transaction type, and the energy-performance and physical characteristics of the property at that address.

5.3 Why we process it (purpose and lawful basis)

We process this data to provide property research, due-diligence, and reporting tools to surveyors and property professionals. Our lawful basis is legitimate interests — namely operating a property-information service that draws on publicly available registers — and we have carried out a Legitimate Interests Assessment balancing this against the rights of the individuals concerned.

5.4 Information about data obtained from other sources (UK GDPR Article 14)

Because some of this personal data is obtained from sources other than the individual it relates to, we provide this notice under Article 14 of the UK GDPR. Much of the underlying data originates from public registers maintained by government bodies. Where contacting each individual directly would involve disproportionate effort, we rely on the exemptions in Article 14(5), and we make this policy publicly available instead.

5.5 Your rights if you are a property owner or occupier

If you are an individual whose property data appears in the Service and you wish to access, object to, or restrict our processing of that data, please contact us using the details in Section 1. We will respond in line with the rights set out in Section 10 and applicable exemptions for publicly available register data.

5.6 Licensing

Property and register data is used under the relevant licences and terms of the supplying bodies (for example, open-data and Crown licences). Users of the Service must comply with those terms — see our Terms & Conditions.

6. Surveyor directory listings and reviews (Surveyor.Directory)

Surveyor.Directory is a public directory of surveying firms and professionals. Some listing information is personal data, particularly where a firm is a sole trader or named individual. This section explains how we handle that data and the reviews submitted about listed firms.

6.1 What we hold in a listing

A listing may include: business/trading name and (where applicable) individual name, business contact details (address, telephone, email, website), areas of practice and professional/accreditation information, and a description of the firm that is generated using AI from publicly available information.

6.2 Where the listing data comes from

We compile listings from publicly available information on the web and from listings that firms submit or are invited to provide. Reviews are submitted by members of the public.

6.3 Why we process it (purpose and lawful basis)

We process listing data to operate a directory that helps the public find surveying firms. Our lawful basis is legitimate interests — operating a professional directory based on publicly available business information — supported by a separate Legitimate Interests Assessment. For reviews, we rely on legitimate interests and on the reviewer's act of submitting the review.

6.4 Information about data obtained from other sources (UK GDPR Article 14)

Where listing data about an identifiable individual is obtained from sources other than that individual (for example, publicly available web sources), this section serves as our Article 14 notice. We make this policy publicly available and, where practicable, contact listed firms directly to make them aware of their listing and how to request changes or removal.

6.5 AI-generated descriptions

Listing descriptions are generated using AI from publicly available information and may contain inaccuracies. They are provided for general information only and do not constitute an endorsement, verification, or recommendation of any firm. If a description is inaccurate, the firm (or any affected person) may request a correction at any time — see Section 6.7.

6.6 Reviews and review verification

Reviews are moderated before publication. We may decline to publish, edit for length or compliance, or remove a review. Reviewers must give honest, first-hand, lawful opinions and must not post false, defamatory, or misleading content.

To verify that a reviewer is a genuine client of the firm being reviewed, we ask reviewers to submit an image of an invoice from that firm. We handle this as follows:

• What we collect: the invoice image and the information visible on it (which may include the reviewer's name and the firm's details). We ask reviewers to redact anything not needed for verification.
• Why / lawful basis: we use the invoice solely to verify the review is genuine. Our lawful basis is legitimate interests (preventing fake reviews and protecting listed firms), together with the reviewer's submission of the document.
• Verification required: if a valid invoice is not supplied, the review will not be published.
• Not published: the invoice image is never published and is used only for verification.
• Retention: we keep the invoice image only for as long as the related review is published, and delete it when the review is removed.

A listed firm may request a right of reply, or ask us to remove a review it believes is inaccurate or unlawful. A firm may also object that an invoice is not genuinely theirs, in which case we remove the review pending a check and reinstate it only if the invoice is shown to be genuine. We assess such requests promptly.

6.7 Your rights if you are a listed firm or individual

If you are listed on Surveyor.Directory, you may at any time and free of charge ask us to:

• correct or update your listing; or
• remove (delist) your listing entirely.

We will action correction and delisting requests promptly. Contact us using the details in Section 1 or via the request route on surveyor.directory. You also have the broader rights set out in Section 10.

7. Who we share data with

We may share personal data with:

• Service providers and sub-processors acting on our behalf — including hosting, cloud storage, payment processing (Stripe), email delivery, content-delivery/security providers (Cloudflare), and OpenAI (AI text-generation for directory descriptions) — under contracts that require equivalent data-protection safeguards. We use first-party/internal tooling for website analytics.
• Professional advisers (e.g. accountants, lawyers, auditors).
• Prospective purchasers of our business, subject to confidentiality.
• Regulators, law enforcement, and other authorities where required by law.

We do not sell your personal data.

8. International transfers

We primarily process personal data within the UK and the European Economic Area (EEA). Where data is transferred outside the UK/EEA, we ensure an appropriate safeguard is in place, such as UK adequacy regulations or the International Data Transfer Agreement / EU Standard Contractual Clauses with the UK Addendum.

9. Payments

Payment-card details are processed by our payment provider, Stripe, and are not stored in full on our systems. Stripe's processing is governed by its own privacy policy (stripe.com/privacy).

10. Your rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase data ("right to be forgotten") in certain circumstances;
• Restrict processing in certain circumstances;
• Object to processing based on legitimate interests or for direct marketing;
• Data portability — receive your data in a usable, machine-readable format;
• Withdraw consent at any time where processing is based on consent;
• Complain to the Information Commissioner's Office (ICO) at ico.org.uk or 0303 123 1113.

To exercise any right, contact us using the details in Section 1. We will respond within one month.

11. Data retention

We keep personal data only for as long as necessary for the purposes set out above:

• Account and customer data — for the life of your account and for a minimum of one year after closure, unless a longer period is required by law (e.g. tax/accounting records, typically six years).
• Property/register data — for as long as it is needed to provide the Service and is consistent with the source licence.
• Directory listings and reviews — for as long as the listing is published; removed on a valid delisting request.
• Technical/log data — retained for 12 months.

12. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Our staff and sub-processors are bound by confidentiality obligations.

13. Changes to this policy

We may update this policy from time to time. The current version is always available on our website, and material changes will be notified where appropriate.

14. Contact

For any privacy question or to exercise your rights: [email protected] — Apaqco Ltd, TAP, 70 Grange Road, East Wirral, CH41 5FE.