Privacy Policy
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1. Who We Are
Eighth Heaven Sourcing Ltd ("we", "us", "our") is a property deal sourcing company registered in England and Wales (Company No. 16070345). We are registered with the Information Commissioner's Office (ICO) for data protection purposes. Our Data Protection Officer is Yuriy Boykov, contactable at info@eighthheavensourcing.com.
2. What Personal Data We Collect
We may collect the following personal data: full name, email address, phone number, property address (where provided), investment budget range, strategy preferences, source of funds information, identity documents (for AML/KYC purposes), and any other information you voluntarily provide through our contact forms or in direct communication with us.
3. How We Collect Your Data
We collect data directly from you when you complete our investor or property enquiry forms, contact us by email or phone, or provide information as part of our AML and KYC onboarding process. We do not purchase data from third parties or use automated data collection tools beyond standard web analytics.
4. Why We Use Your Data (Legal Basis)
We process your personal data on the following legal bases: (a) Legitimate interests — to respond to your enquiry and assess suitability for our services; (b) Legal obligation — to carry out identity verification and anti-money laundering checks as required under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; (c) Consent — where you have given us specific permission to contact you with relevant opportunities.
5. How We Use Your Data
We use your data to: respond to investor and property enquiries; assess suitability and match investors with appropriate opportunities; complete required AML, KYC and source-of-funds verification; communicate relevant deal opportunities to registered investors; meet our legal and regulatory obligations; and improve the quality of our service.
6. Who We Share Your Data With
We may share your data with trusted third-party service providers who assist us in delivering our services. These may include: Credas (identity verification and AML checks); Etsos (property search and due diligence); Zeevou (property management and tenancy software); and our legal and compliance advisers. All third parties are required to process your data securely and in accordance with applicable data protection law. We do not sell your data.
7. International Transfers
Where we transfer personal data outside the UK or European Economic Area, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the relevant supervisory authority, or we rely on an adequacy decision.
8. Data Retention
We retain personal data for as long as necessary to fulfil the purpose for which it was collected and to comply with our legal obligations. AML and KYC records are retained for a minimum of five years from the end of our business relationship, in line with HMRC requirements. Enquiry data from individuals who do not proceed to a transaction is retained for up to two years.
9. Your Rights
Under UK GDPR, you have the right to: access the personal data we hold about you; request correction of inaccurate data; request erasure of your data (subject to legal obligations); object to or restrict processing; request data portability; and withdraw consent at any time where processing is based on consent. To exercise any of these rights, contact us at info@eighthheavensourcing.com. You also have the right to lodge a complaint with the ICO at ico.org.uk.
10. Cookies
Our website may use essential cookies to ensure basic functionality. We do not currently use advertising or tracking cookies. If this changes, we will update this policy and seek your consent as required.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The current version will always be available on this page with the date of last update noted. Continued use of our website following any update constitutes acceptance of the revised policy.
12. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer: Yuriy Boykov — info@eighthheavensourcing.com — Eighth Heaven Sourcing Ltd, England and Wales.
For any queries regarding this document, please contact us at info@eighthheavensourcing.com.