Privacy Policy
Last updated: February 2026
1. Data controller
open for offer is a trading name of OMPT Group Limited, a company registered in England and Wales (company number 13206639) whose registered office is at 22 St Peters Street, Stamford, England, PE9 2PF. We are the data controller for personal data collected through openforoffer.com (“the Platform”).
We have not appointed a dedicated Data Protection Officer as this is not required under Article 37 of UK GDPR given the current scale of our operations. Our Data Protection Team handles all data protection matters and can be contacted at privacy@openforoffer.com.
We are registered with the Information Commissioner’s Office (ICO) under registration reference ZB718578. You have the right to lodge a complaint with the ICO at any time: ico.org.uk/make-a-complaint.
2. Personal data we collect
We collect and process the following categories of personal data:
Data you provide directly
- Account data: Name, email address, phone number, and authentication credentials when you create an account.
- Property data: Property details including address, description, features, EPC rating, council tax band, tenure, and photographs.
- Offer data: Offer amounts, buyer financial position, chain status, and preferred timelines.
- Identity verification data: Photographic ID (passport, driving licence), proof of address, proof of funds, and biometric data (facial comparison for identity matching).
- Communication data: Messages sent between buyers and sellers through our messaging system.
Data we collect automatically
- Usage data: Pages visited, search queries, property views, saves, and interaction patterns.
- Device data: IP address (hashed for analytics), browser type, operating system, and screen resolution.
- Cookie data: See our Cookie Policy for details.
Data from third parties
- Authentication providers: If you sign in via Google, Apple, or Facebook, we receive your name and email address from the identity provider.
- Payment data: Stripe provides us with transaction confirmation and limited billing details. We do not receive or store your full card number.
- Public property data: We enrich listings with publicly available data from HM Land Registry, the EPC Register, the Valuation Office Agency, and the Environment Agency.
3. How and why we use your data
We process your personal data for the following purposes and under the following legal bases (as defined by UK GDPR Article 6):
| Purpose | Legal basis |
|---|---|
| Provide and operate the Platform (account management, listing publication, offer processing, messaging) | Contract performance (Article 6(1)(b)) |
| Process payments and manage subscriptions | Contract performance (Article 6(1)(b)) |
| Verify identity, prevent fraud, and comply with AML/KYC regulations | Legal obligation (Article 6(1)(c)) |
| Generate AI-powered property valuations | Contract performance / Legitimate interest |
| Send service-related emails (offer notifications, account updates, security alerts) | Contract performance (Article 6(1)(b)) |
| Send marketing communications (property match alerts, weekly digest, promotions) | Consent (Article 6(1)(a)) |
| Improve the Platform, analyse usage patterns, and develop new features | Legitimate interest (Article 6(1)(f)) |
| Screen against sanctions lists and PEP databases | Legal obligation (Article 6(1)(c)) |
| Introduce you to mortgage brokers (where you request this) | Consent (Article 6(1)(a)) |
| Calculate Mover Score and behavioural engagement metrics, personalise property recommendations, and detect non-genuine users | Legitimate interest (Article 6(1)(f)) |
4. Automated decision-making and AI processing
We use automated processing in the following ways:
- AI property valuations: Automated estimates generated from publicly available data. These do not produce legal effects or similarly significantly affect you. They are provided as informational tools only.
- Property matching: Automated matching of properties to buyer search preferences. You can modify your preferences at any time.
- Identity verification: Automated comparison of your selfie to your identity document. Where automated verification fails, a manual review process is available.
Under Article 22 of UK GDPR, you have the right not to be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect you. Where we use automated processing, you have the right to request human review of any decision by contacting privacy@openforoffer.com.
5. Behavioural analytics and profiling
We analyse how you interact with the Platform to calculate a “Mover Score” — a composite metric (0–100) that reflects your readiness as a buyer or seller. The score is visible on your dashboard and its tier (Bronze, Silver, Gold, or Platinum) may be visible to counterparties in offer contexts to help build trust.
What feeds into your Mover Score
- Profile completion: Whether you have provided a verified email, phone number, profile photo, search preferences, and identity documents.
- Verification level: Your email verification status, phone verification, and KYC completion stage.
- Engagement signals: Property views, saves, time spent browsing, and session frequency — all derived from first-party usage data (we do not track you across other websites).
- Offer quality: Number of offers made, proportion accompanied by proof of funds or a mortgage agreement in principle, and completion rate.
- Market activity: Properties viewed and saved, offers submitted, and account tenure.
How we use behavioural data
- Personalised recommendations: Your browsing history and search preferences are used to rank and suggest properties that may interest you. This processing is performed entirely on our own infrastructure using first-party data.
- Engagement analysis: We aggregate interaction patterns (e.g., average time on property pages, save-to-view ratio) to improve the Platform and identify areas where users encounter difficulty.
- Non-genuine user detection: Unusual activity patterns may be flagged for review to protect sellers from time-wasters and fraudulent offers.
Legal basis and your rights
We process this data under Article 6(1)(f) — legitimate interest. Our Legitimate Interest Assessment concluded that the benefits to both buyers (relevant recommendations, faster transactions) and sellers (identifying serious buyers, reducing fall-through rates) outweigh any privacy impact, particularly as the data is first-party only and no data is shared with external advertisers.
You have the right to object to profiling at any time by emailing privacy@openforoffer.com with the subject line “Object to profiling”. If you object, we will stop behavioural scoring for your account within 7 working days. This may limit the personalisation features available to you.
6. Property address privacy
We take address privacy seriously. Full property addresses are never displayed publicly on the Platform. Buyers see only an anonymised address (area name and partial postcode) until the seller explicitly chooses to share their full address with a specific buyer. Postcodes are truncated to the outward code only (e.g., “SW1A”) in all public-facing contexts.
8. Your rights under UK GDPR
You have the following rights in relation to your personal data:
- Right of access (Article 15): Request a copy of all personal data we hold about you.
- Right to rectification (Article 16): Request correction of inaccurate or incomplete data.
- Right to erasure (Article 17): Request deletion of your data, subject to our legal retention obligations (see section 9).
- Right to restrict processing (Article 18): Request that we limit how we use your data.
- Right to data portability (Article 20): Receive your data in a machine-readable format (JSON) for transfer to another provider.
- Right to object (Article 21): Object to processing based on legitimate interests, including direct marketing.
- Right to withdraw consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
You can exercise many of these rights directly through your account on our Data Rights page. For more complex requests, email privacy@openforoffer.com with the subject line “Data Subject Request”. We will respond within one calendar month. We may ask you to verify your identity before processing your request. If your request is complex or we receive a high volume of requests, we may extend the response period by a further two months, and we will notify you of this.
9. Data retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:
- Account data: Retained while your account is active, then deleted within 30 days of account closure (unless retention is required by law).
- Property and offer data: Retained for 6 years after the transaction completes or the listing is withdrawn, to comply with the Limitation Act 1980 (contract claims).
- AML/KYC records: Retained for 5 years after the business relationship ends, as required by the Money Laundering Regulations 2017.
- Financial records: Retained for 6 years as required by HMRC.
- Usage and analytics data: Anonymised after 26 months. Anonymised data is not personal data and may be retained indefinitely.
10. How we protect your data
We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (TLS 1.3) and at rest (AES-256), access controls with role-based permissions, regular security audits and penetration testing, and incident response procedures. Our infrastructure is hosted in AWS eu-west-2 (London) with data residency in the UK for primary databases.
11. Data breach notification
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware of the breach, as required by Article 33 of UK GDPR. If the breach is likely to result in a high risk to you, we will notify you directly without undue delay (Article 34).
12. Children
The Platform is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately at privacy@openforoffer.com.
13. Changes to this policy
We may update this privacy policy from time to time. Material changes will be notified to you by email. The “last updated” date at the top of this page indicates when the policy was last revised.
14. Contact us
For privacy-related enquiries:
Data Protection Team
OMPT Group Limited (trading as open for offer)
22 St Peters Street, Stamford, England, PE9 2PF
Company number: 13206639
Email: privacy@openforoffer.com
ICO: ico.org.uk