Privacy Policy

Off/Market Exchange Ltd is the data controller for all personal data collected through this website and the Off/Market Exchange platform. We are registered at Manchester One, 53 Portland Street, Manchester M1 3LD, Companies House number 17163711.

If you have any questions about how we handle your data, contact us at max@rothmoreproperty.com.

When you apply for membership or use the platform, we collect the following categories of personal data:

• —Identity data: your name, job title, and company name
• —Contact data: your email address and telephone number
• —Professional data: details of your role, the types of assets you work with, and your deal activity on the platform
• —Transaction data: records of assets you have listed, offers you have submitted, and deals you have completed through the exchange
• —Compliance data: copies of Terms of Business and other documents you upload to verify mandates
• —Technical data: your IP address, browser type, and usage data collected when you access the website or platform
• —Communications: any correspondence you send to us by email or through the platform

We do not collect sensitive personal data (such as health information, financial account details, or biometric data) in the ordinary course of operating the platform.

We use the data we collect for the following purposes:

• —To process and assess your membership application
• —To operate and administer your account on the platform
• —To verify asset listings and mandates submitted to the exchange
• —To facilitate deals between members, including sharing relevant contact and deal details with your counterparty
• —To invoice and collect platform fees on completed deals
• —To comply with our legal and regulatory obligations, including anti-money laundering requirements
• —To communicate with you about your membership, deals, and platform updates
• —To improve the platform and understand how members use it

We process your personal data on the following legal bases:

• —Contract: processing is necessary to perform our obligations under the Membership Agreement
• —Legitimate interests: to operate the exchange, prevent fraud, and maintain the integrity of the platform
• —Legal obligation: to comply with AML, KYC, and other applicable legal requirements
• —Consent: where you have provided explicit consent for a specific processing activity

We do not sell your personal data to third parties. We do not share your data with third parties for marketing purposes.

We share data only in the following limited circumstances:

• —With your counterparty in a deal: when an offer proceeds, your professional contact details are shared with the other member involved in that deal
• —With service providers: we use third-party software providers (including HubSpot for CRM, Vercel for hosting, and DocuSign for e-signature) who process data on our behalf under data processing agreements
• —With regulators or law enforcement: where required to do so by law, court order, or a regulatory authority

All third-party providers are required to handle your data securely and in accordance with applicable data protection law. They may not use your data for their own purposes.

We retain your personal data for as long as your membership remains active and for a period of 7 years following the closure or termination of your membership. This retention period reflects our obligations under AML legislation and enables us to resolve any disputes relating to deals completed on the platform.

Technical and usage data may be retained for shorter periods in line with standard system log retention practices.

Under UK data protection law, you have the following rights in relation to your personal data:

• —Access: you may request a copy of the personal data we hold about you
• —Correction: you may ask us to correct inaccurate or incomplete data
• —Deletion: you may request that we delete your personal data where there is no legitimate reason for us to continue processing it
• —Restriction: you may ask us to restrict processing of your data in certain circumstances
• —Portability: you may request your data in a structured, machine-readable format
• —Objection: you may object to processing carried out on the basis of our legitimate interests

To exercise any of these rights, including a request for deletion of your personal data, please email max@rothmoreproperty.com. We will respond within 30 days. Please note that some rights are subject to legal exemptions and may not apply in all circumstances.

This website uses functional cookies necessary for the operation of the site, including session management and authentication. We do not use advertising or tracking cookies. We do not share cookie data with third parties for profiling purposes.

We take the security of your personal data seriously. The platform uses industry-standard encryption in transit and at rest. Access to personal data is restricted to authorised personnel only. We review our security practices regularly.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Information Commissioner's Office as required by law.

We may update this Privacy Policy from time to time. Any material changes will be communicated to members by email. The current version of this policy is always available on this page. Continued use of the platform following notification of changes constitutes acceptance of the updated policy.

If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO.