Privacy Policy

James Anthony & Co is the trading name of James Anthony McDonaugh Limited, a company registered in England and Wales (company number 17266182) with its registered office at 23 Berkeley Square, London W1J 6HE. In this policy, “we”, “us” and “our” refer to James Anthony McDonaugh Limited, which is the controller of the personal data described below.

This policy explains how we collect, use and protect personal data when you visit our website at jamesanthonyandco.com, subscribe to our letters at letters.jamesanthonyandco.com, make an enquiry, or engage us as a client. We take privacy seriously and handle personal data in accordance with the UK General Data Protection Regulation and the Data Protection Act 2018.

Questions about this policy, or about how we handle your data, should be addressed to property@jamesanthonyandco.com or by post to the registered office above.

Who we are and what we do

We are a London-based buyer’s advisory practice. We act exclusively for buyers, advising international clients on the acquisition of residential and rural property in Uruguay. Because of the nature of our work, we handle personal data belonging to prospective clients, clients, professional contacts and referrers, and — during anti-money laundering checks — certain third parties connected to a transaction.

The personal data we collect

Website visitors. When you browse our website, we collect limited technical data — such as IP address, browser type, device information and pages visited — through our hosting provider and, where you consent via our cookie banner, through Google Analytics. This data is used in aggregate to understand how the site is used and to keep it secure.

Enquirers. If you contact us through the website, by email or at an event, we collect the details you choose to give us: typically, your name, email address, telephone number, country of residence and the substance of your enquiry, including your interest in Uruguay.

Newsletter subscribers. Our letters are published through Substack. If you subscribe, Substack collects your email address and standard engagement data (such as opens) on our behalf. Substack’s own privacy policy also applies to its platform.

Clients. If you engage us, we collect the information needed to perform the engagement: contact details, your property requirements and preferences, correspondence, and details relevant to trip planning and transaction coordination. Where you give us personal data about others connected to your purchase — for example a spouse, family member, representative or beneficiary — please make sure they are aware of this policy.

Client due diligence. We are supervised by HM Revenue & Customs for anti-money laundering purposes. Before and during an engagement we are legally required to verify your identity and assess the source of funds and wealth for a proposed purchase. This involves collecting identity documents (such as passport and proof of address), financial information, and the results of screening against sanctions, politically exposed person and adverse media databases. Specialist checks are carried out on our behalf by our compliance provider. Where a transaction involves other parties — for example a seller — we may also process limited personal data about them as part of our due diligence. These checks may reveal information about criminal convictions, alleged offences or other sensitive matters. We process such data only as permitted by Schedule 1 to the Data Protection Act 2018, the conditions relating to preventing or detecting unlawful acts and complying with regulatory requirements.

Where your data comes from. Most of the data we hold comes directly from you. We may also receive personal data from referrers and professional contacts who introduce you to us, from screening databases and publicly available sources during due diligence, and from our Uruguayan partners during a transaction.

How we use personal data, and on what legal basis

• Responding to enquiries — we rely on our legitimate interests in operating and promoting our practice, and in corresponding with people who contact us.
• Performing a client engagement — processing is necessary for the performance of our contract with you, or to take steps at your request before entering it.
• Anti-money laundering and sanctions compliance — processing is necessary to comply with our legal obligations, principally under the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002 and UK sanctions legislation. Because our work involves Uruguayan property, transactions are also subject to Uruguay’s anti-money laundering framework (Law No. 19,574, overseen by SENACLAFT, the national anti-money laundering secretariat), under which notaries and licensed real estate intermediaries carry out their own due diligence; where we process data to support compliance with those requirements, we rely on our legitimate interests in conducting transactions lawfully in both jurisdictions. We cannot act for a client without completing these checks.
• Sending our letters — we rely on your consent, given when you subscribe. You can unsubscribe at any time using the link in any email.
• Improving and securing the website — we rely on our legitimate interests in running an effective, secure website; analytics cookies are set only with your consent.
• Keeping business records — we rely on our legal obligations (for example under tax and company law) and our legitimate interests in maintaining proper records of our work.

We do not use personal data for automated decision-making, and we never sell personal data.

Who we share personal data with

We share personal data only where necessary to run our practice and deliver our services, with:

• our compliance provider, which conducts client due diligence checks on our behalf;
• our professional advisers, including our UK and Uruguayan lawyers and our accountants, where relevant to an engagement or to our own affairs;
• trusted Uruguayan partners — such as licensed local agents, notaries and lawyers — when, and only to the extent, needed to progress a search or transaction on your instructions;
• service providers who support our operations, including our website host, domain and security services, email and productivity platform (Google Workspace), and Substack for our letters;
• regulators, law enforcement or other authorities where we are legally required to do so, including HM Revenue & Customs as our anti-money laundering supervisor and, where the law requires it, the National Crime Agency.

International transfers

Our work is inherently cross-border. Where an engagement involves Uruguay, relevant personal data will be shared with our partners and advisers there; Uruguay benefits from a UK adequacy decision, meaning UK law recognises its data protection regime as providing an equivalent standard of protection. Some of our service providers — including Substack and Google — process data in the United States; where they do, we rely on the UK Extension to the EU–US Data Privacy Framework or on contractual safeguards approved for use under UK law. Where data is processed elsewhere in the European Economic Area, it is covered by the UK’s adequacy regulations for the EEA.

How long we keep personal data

We keep personal data only as long as we need it. As a guide: enquiry records that do not lead to an engagement are kept for up to two years; client files are kept for six years after the end of an engagement, in line with tax and limitation requirements; and client due diligence records are kept for five years after the end of the business relationship, or after completion of the checks where an engagement does not proceed, as the Money Laundering Regulations require. Newsletter data is held for as long as you remain subscribed. When data is no longer needed, it is securely deleted.

Cookies

Our website uses a small number of cookies. Essential cookies are needed for the site to function and to record your cookie preferences. Analytics cookies (Google Analytics) help us understand how the site is used and are set only if you accept them via the cookie banner; you can change your choice at any time. The letters pages at letters.jamesanthonyandco.com are served by Substack, which sets its own cookies subject to its own policy.

Cookies set by this website

Cookie	Purpose	Duration
jac_consent	Essential. Remembers whether you accepted or declined analytics cookies, so that we do not ask again on every visit.	6 months
_ga	Analytics (Google Analytics). Distinguishes one visitor from another. Set only if you accept.	13 months
_ga_J7Q42Z97B5	Analytics (Google Analytics). Maintains the state of your visit. Set only if you accept.	13 months

You can change your choice at any time using the “Cookie settings” link at the foot of any page. If you withdraw your consent, the analytics cookies are deleted from your browser.

Security

We apply appropriate technical and organisational measures to protect personal data, including access controls, reputable hosting and security services, and careful limits on who within the practice and among our partners can see client information. Due diligence material is handled on a strict need-to-know basis.

Your rights

Under UK data protection law you have the right to:

• request access to the personal data we hold about you;
• have inaccurate data corrected and, in certain circumstances, have data erased;
• restrict or object to our processing, including any processing based on legitimate interests;
• receive certain data in a portable format;
• withdraw consent at any time where processing is based on consent (for example, our letters or analytics cookies).

To exercise any of these rights, contact us at property@jamesanthonyandco.com. We will respond within one month. Please note that some rights are limited where we are under a legal duty to retain or process data — in particular, we cannot delete due diligence records that the Money Laundering Regulations require us to keep.

If you are unhappy with how we have handled your data, you can complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113, though we would welcome the chance to resolve any concern with you directly first.

Children

Our website and services are directed at adults. We do not knowingly collect personal data from anyone under 18.

Third-party links

Our website and letters may link to third-party sites, including property listings and publications. We are not responsible for the privacy practices of those sites, and we encourage you to read their policies.

Changes to this policy

We may update this policy from time to time as our services or the law change. The current version will always be available on our website, with the date of the last update shown at the top.

Return to the home page