Data & Privacy Policy

01 About us and this policy

Odessia Real Estate is a trading name of Odessia Holdings Ltd, a company registered in England and Wales under company number 16198632, whose registered office is at 8 High Street, Morcott, Oakham, England, LE15 9DN (“Odessia”, “we”, “us” or “our”). We are the controller of the personal information described in this policy.

It applies to our website at www.odessia.co.uk, to our dealings with you by email, phone, in person or otherwise, and to the information about people and organisations active in our markets that we hold in our internal client register. It is written for clients and prospective clients, the people we introduce or may introduce to opportunities, the agents and advisers we deal with, and visitors to our website.

If you have any questions about this policy or how we handle your data, contact us at contact@odessia.co.uk or write to us at the address above.

02 The information we collect

Depending on how we deal with you, we may hold:

• Identity and contact details — your name, job title, the organisation you work for, and your business address, email address and phone numbers.
• Property and requirement information — properties you own, occupy, are marketing or are interested in; what you are looking for (sector, location, size, budget, appetite for planning risk); and information relevant to an instruction or transaction, including offers and their terms.
• Records of our dealings with you — notes of calls, meetings and correspondence; properties we have introduced to you and your feedback on them; tasks and reminders relating to you; and our own working notes, such as when we last spoke.
• Communications — the content of enquiries, messages and correspondence between us.
• Verification information — where we must confirm your identity or carry out anti-money-laundering (“AML”) checks, identity documents and related information.
• Technical information — when you visit our website, your IP address and browser and device information in our host’s server logs and, only if you accept analytics cookies, information about how you use the site.

03 Where it comes from

Most of what we hold comes from you — when you enquire about a property, ask us to act for you, exchange details with us at a viewing or meeting, or contact us by phone, email, our website, social media or in person.

We also gather information about people and organisations active in the property markets we work in, so that we can bring the right opportunities to the right people. This is a normal part of running a property advisory business, and it comes from:

• public registers and sources — Companies House, HM Land Registry, local authority planning registers, and the property press;
• professional networks and property portals — for example LinkedIn, Rightmove, Zoopla and commercial listing services;
• other parties to a transaction — an agent, solicitor or adviser who introduces you, or who acts for the other side;
• referrals and introductions from our clients and contacts.

Where we obtain information about you in this way, we will tell you we hold it when we first contact you, and no later than a month after we collect it; this policy is that notice. You can ask us at any time what we hold and where it came from, and you can ask us to stop (section 11).

Where we verify identity or meet our AML obligations, we may also receive information from identity-verification and credit reference agencies.

04 Why we use your information, and our lawful bases

We use your personal information for the following purposes, on the lawful bases set out alongside each:

• To respond to enquiries and provide our services — advising on, marketing, acquiring, selling or letting property on your instructions — because it is necessary to perform a contract with you, or to take steps at your request before entering into one.
• To keep a register of the markets we work in — who owns, buys, sells, occupies, funds and advises on property in London and the Home Counties, and what they are looking for — on the basis of our legitimate interests. A property advisory business cannot function without knowing this. We hold only what a business contact would expect us to hold, we have weighed our interest against your rights, and you can object at any time.
• To match properties to the people most likely to want them, and to make introductions — on the basis of our legitimate interests and, where you have instructed us, our contract with you.
• To keep you informed about a property, requirement or transaction you are involved in — on the basis of our legitimate interests in running instructions properly.
• To contact you about opportunities and our services — see section 5.
• To verify identity and comply with legal and regulatory obligations — including AML, accounting and tax requirements — because it is necessary to comply with the law.
• To keep records and to establish, exercise or defend legal claims — on the basis of our legitimate interests.
• To run and improve our website — on the basis of our legitimate interests for the site itself, and your consent for analytics cookies.

Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights and concluded that they are not. You can ask us for more detail about that assessment.

05 Marketing and keeping in touch

Most of the people we contact are acting for a business. Where we contact you at work about property opportunities or our services, we rely on our legitimate interests. Where the law requires your consent first — for example, marketing to a personal email address, or to a sole trader or partnership — we will ask for it.

You can ask us to stop at any time by replying to a message or emailing contact@odessia.co.uk. We will stop straight away, and we keep a note of your request so that we do not contact you again.

06 Who we share it with

We do not sell your personal information. We may share it with:

• Other parties to a transaction. When we introduce you to a property or to another party, or act for you in a transaction, we share the details needed to make the introduction and progress the matter — with buyers, sellers, landlords, tenants, and their agents, solicitors and other advisers.
• Providers who process data on our behalf — the company that hosts our website (Netlify); the service that hosts our client register (Supabase, on servers in the United Kingdom); our email, document storage and office software providers; and, only where you have accepted analytics cookies, Google Analytics. Each is bound by contract to keep your information secure and to use it only on our instructions.
• Property portals and marketing services, where you have asked us to market a property.
• Professional advisers — our legal, accounting and IT advisers, who are bound by duties of confidentiality.
• Authorities, regulators, redress schemes and courts, where we are required to by law, to meet our AML obligations, or to establish, exercise or defend legal claims.
• A buyer or successor of our business, if our business or its assets are sold or reorganised, on terms that protect your information.

07 International transfers

Our client register is hosted in the United Kingdom. Some of our providers — for example our website host and Google — are based in the United States or may support their services from outside the UK. Where information leaves the UK we rely on the UK Government’s adequacy regulations (including the UK–US Data Bridge, where the provider is certified under it) or on approved contract terms — the ICO’s International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses. You can contact us for more information about these safeguards.

08 How long we keep it

We keep personal information only for as long as we need it for the purposes above, then delete or anonymise it. In particular:

• Our register of market contacts — while you remain active in the markets we work in and we have a reason to be in touch. We review it regularly, remove people we have had no dealings with for some time, and remove you promptly if you ask.
• Client and transaction records — for the life of the instruction and six years afterwards, to meet our legal, accounting and tax obligations and to deal with any claim.
• AML and identity records — five years after the end of the business relationship, as the law requires.
• General enquiries that do not lead to an instruction — for a limited period after our last contact.
• Requests not to be contacted — indefinitely, so that we honour them.
• Website analytics, if you accept them — Google Analytics is set to keep the data for no more than fourteen months.

09 How we keep it secure

Our website and client register are served over encrypted (HTTPS/TLS) connections. The register is hosted in the United Kingdom, encrypted at rest, and can only be reached by named members of our team, each with their own login, which we remove when someone leaves. We keep what we hold to what we need. No method of transmission over the internet or of electronic storage is completely secure, so please avoid sending us sensitive information by email where you can, and tell us at once if you believe your information has been compromised.

10 Cookies and our website

Our website sets no cookies unless you accept analytics. One strictly necessary item is kept in your browser to remember your choice. If you accept, Google Analytics sets cookies that help us see how the site is used; if you do not, it never loads. Our host, Netlify, keeps standard server logs (IP address, browser, pages requested) for security and to run the service, and the site loads its typefaces from Google Fonts and its images from a content delivery network, each of which receives your IP address in order to send the file. Details are in our Cookies Policy.

11 Your rights

Under data protection law you have the right to:

• access the personal information we hold about you, and be told where it came from;
• ask us to correct information that is inaccurate or incomplete;
• ask us to erase your information in certain circumstances — including where we hold it on the basis of legitimate interests and you object;
• object to processing based on our legitimate interests, including your inclusion in our register of market contacts, and to direct marketing at any time — we will stop unless we have compelling grounds, and for direct marketing we will always stop;
• ask us to restrict our processing in certain circumstances;
• request the portability of information you have provided to us;
• withdraw your consent at any time, where we rely on consent; and
• not be subject to decisions producing legal effects based solely on automated processing (we do not make such decisions).

To exercise any of these rights, email contact@odessia.co.uk. We do not charge, we may need to confirm your identity, and we will respond within one month.

If you are unhappy with how we have handled your personal information, you have the right to complain to the Information Commissioner’s Office (ICO). We would appreciate the chance to address your concerns first, so please do contact us. You can reach the ICO at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF · Helpline: 0303 123 1113 · ico.org.uk.

12 Changes to this policy

We may update this policy from time to time. When we do, we will post the updated version on this page and change the “last updated” date above. Where the changes are material, we will take reasonable steps to bring them to your attention.

13 How to contact us

If you would like to access, correct or delete your information, exercise any of your rights, raise a concern or simply find out more, please contact us at contact@odessia.co.uk or write to us at 8 High Street, Morcott, Oakham, England, LE15 9DN.