Privacy Policy

1. Who we are

4walls Commercial Ltd, trading as 4WALLS Spaces ("4WALLS Spaces", "we", "us"), is the data controller for the personal data described in this policy. The company is registered in England and Wales (Company No. 17244725) at 16 Royal Crescent, Cheltenham GL50 3DA.

4WALLS Spaces operates 4wallsspaces.com, an AI-powered search platform for UK commercial property — warehouse and industrial units, offices, workshops, studios, storage, retail and land. We are a lead-routing platform, not an agent acting for you. We do not carry out viewings, negotiate terms, qualify enquirers, or provide any ancillary service such as mortgage, finance or conveyancing referrals.

This policy describes processing under the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR). For data protection queries, contact hello@4wallsspaces.com.

2. Our business-to-business context

4WALLS Spaces is a business-to-business service. Enquiries are made by businesses looking to lease or acquire commercial space, and the details submitted are business contact details given in a professional capacity — your name, your work email address, your work telephone number and your company.

Most of the information we hold is company information rather than personal data. Where business contact details do identify an individual, they are personal data and this policy applies to them.

We do not knowingly collect data about consumers acting outside a business capacity, and the service is not directed at individuals in a personal capacity.

3. Personal data we collect

Enquiry data. When you register interest in a space, we collect your name, work email address, telephone number, company name, the property you enquired about, and any requirement details you choose to give (space required, location, timeframe, budget, and free-text comments).

Landlord and operator portal data. Where you are a landlord, asset manager, operator or agent using our portal, we collect your name, work email address, telephone number, company, job role and account login credentials.

Listing data. Our listings are compiled from information supplied by our partners and from publicly available commercial property listings. This is predominantly company and property information, but it can include the business contact details of the marketing agent or landlord representative named on a listing.

Technical data. IP address, device type, browser and pages visited, collected via cookies and similar technologies where you consent (see Section 8).

We do not collect special category data, we do not record telephone calls, and we do not carry out credit, affordability or identity checks on enquirers.

4. How we use your data and our lawful basis

Routing your enquiry to the landlord or operator. UK GDPR Article 6(1)(b) — steps taken at your request prior to entering a contract — and Article 6(1)(f), our legitimate interest in operating a commercial property lead platform. Submitting an enquiry is your request to be introduced to that landlord or operator.

Operating landlord and operator accounts on the portal. Article 6(1)(b) where you hold an account with us, and Article 6(1)(f), our legitimate interest in administering the platform and communicating with our partners about their listings and leads.

Compiling and enhancing listings, including the business contact details of the agent or representative named on a public listing. Article 6(1)(f), our legitimate interest in maintaining an accurate commercial property index. We use AI tools to structure, summarise and improve the quality of listing content.

Measuring how our listings perform in search, including AI assistants and search engines. Article 6(1)(f) for aggregated, non-identifying search reporting, and Article 6(1)(a) consent for any analytics cookies (see Section 8).

Meeting legal obligations, including HMRC record-keeping and responding to lawful requests. Article 6(1)(c).

You are not legally obliged to give us your data, but we cannot pass your enquiry to the landlord or operator without the information described above.

5. What we do not do

We think it is worth being explicit about the things this platform does not do, because it materially limits the processing described in this policy:

• We do not contact you about your enquiry. Your enquiry goes directly to the landlord or operator. We do not call, email, text or message you about it, and we do not send you marketing.
• We do not qualify or vet you. We do not assess your covenant strength, budget, funding or suitability. That is entirely a matter between you and the landlord.
• We do not record calls. We operate no call centre and no call recording for enquirers.
• We do not offer ancillary services. There are no mortgage, finance, insurance, conveyancing or legal referrals, and we receive no referral fees from any such provider.
• We do not use Meta services. We do not operate a Meta Pixel or Conversions API, we do not run advertising on Meta platforms, and we do not build custom or look-alike advertising audiences from your data.
• We do not sell your data, and we do not share it with any landlord or operator other than the one whose space you enquired about.

6. Who we share your data with

Within 4WALLS Spaces, access is limited to directors and employees who need it. External sharing occurs only as described below.

6.1 The landlord, operator or their agent

When you submit an enquiry about a space, your enquiry is passed directly into the CRM of the landlord, operator or managing agent responsible for that space. This includes your name, work email address, telephone number, company name, the property enquired about and any requirement details you provided.

From that point the landlord, operator or agent is an independent controller of your data and handles it under their own privacy notice. They — not we — decide how to contact you, what to keep and for how long. We do not control, and are not responsible for, their processing.

Your data is only ever shared with the specific landlord or operator whose space you enquired about. We do not share it with any landlord or operator you have not enquired about, and we do not circulate your enquiry to a panel.

6.2 The landlord and operator portal

We operate a portal giving each landlord or operator visibility of the enquiries relating to their own listings. Through the portal, a partner can see the enquirer's name, company, contact details, requirement details, and the time-stamp and status of the enquiry. Partners see only enquiries relating to their own listings.

6.3 Technology providers

We use third-party providers to host the platform, deliver email, store data and provide AI-assisted listing content. These providers act as processors under Article 28 UK GDPR, act only on our written instructions, and do not use the data for their own purposes. Content submitted to our AI providers for listing enhancement is not used to train their models.

6.4 Search platforms

We use Google Search Console and Microsoft Bing Webmaster Tools to understand how our listings are found and to improve their visibility in search engines and AI assistants such as ChatGPT, Claude, Gemini and Perplexity. These tools report aggregated search performance — queries, impressions, clicks and positions — and do not identify individual users to us. We do not upload enquiry data or customer lists to any search or advertising platform.

6.5 Other recipients

We may share personal data with professional advisers under a duty of confidentiality, with a purchaser or investor in connection with a corporate transaction, and with regulators, law-enforcement agencies or courts where required by law.

7. Communications

We do not send marketing to enquirers. Because your enquiry is routed straight to the landlord or operator, any communication you receive about the space comes from them under their own privacy notice and their own marketing permissions.

If you hold a landlord, operator or agent account with us, we will send you service messages about your account, your listings and the enquiries you receive, and we may send you business-to-business marketing about our services in reliance on Article 6(1)(f) and, where applicable, the PECR business-to-business rules for corporate subscribers. You can opt out at any time, free of charge, by clicking unsubscribe in any marketing email or emailing hello@4wallsspaces.com.

8. Cookies and tracking

We use cookies that are strictly necessary for the site to function, and — where you consent through our cookie banner — analytics cookies that help us understand how the site is used. We do not use advertising or social media tracking pixels.

Analytics cookies rely on your consent under PECR Regulation 6 and UK GDPR Article 6(1)(a). You can withdraw consent at any time by changing your cookie preferences on the website or blocking cookies in your browser. Withdrawal does not affect the lawfulness of processing before withdrawal.

9. International transfers

Where personal data is transferred outside the UK — for example to a hosting, email or AI provider — we rely on UK adequacy regulations, the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses together with the UK Addendum.

10. How long we keep your data

• Enquiry records: 12 months from the date of the enquiry, after which they are securely deleted or anonymised. The landlord or operator who received your enquiry keeps their own copy under their own retention policy.
• Landlord, operator and agent account data: for the duration of the account and 12 months after it is closed.
• Listing contact details taken from public sources: for as long as the listing is live, and 6 months afterwards.
• Transaction and commission records: 6 years from the end of the relevant financial year, to meet HMRC and accounting requirements.

11. Your rights

Under UK GDPR you have the right to access your data, correct inaccurate data, ask us to delete your data, restrict or object to our processing, receive your data in a portable format, and withdraw any consent you have given.

Because your enquiry is passed to an independent controller, a request to delete your data from our systems does not delete it from the landlord's or operator's CRM. You will need to contact them directly for that, and we will tell you who they are if you ask.

To exercise any right, contact hello@4wallsspaces.com. We respond within one calendar month.

12. Complaints

If you are unhappy with how we have handled your personal data, please contact us first at hello@4wallsspaces.comso we can try to put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.

13. Changes to this policy

We may update this policy from time to time. The "Last updated" date above shows the most recent revision.