Privacy Policy

1. Who we are

This website, openaddress.co.uk ("OpenAddress", "we", "us", "our"), is operated by OpenAddress Ltd, a company registered in Northern Ireland (company number NI741612), with its registered office at: OpenAddress Ltd, Ground Floor, Gallery Building, 65-69 Dublin Road, Belfast, BT2 7HG.

OpenAddress Ltd is the data controller responsible for your personal data when you use this website.

We are registered with the Information Commissioner's Office (ICO), registration number ZC179457.

If you have any questions about this policy or about how we handle your personal data, you can contact us at hello@openaddress.co.uk.

2. What OpenAddress is (and is not)

OpenAddress is a peer-to-peer advertising and introduction platform. It lets a prospective buyer pay a flat fee to send a physical letter to a residential property, expressing interest in buying that property, and - if the homeowner chooses to respond - lets the two parties communicate through the platform.

OpenAddress is not an estate agent. We do not value, market, or sell property, we do not act for any seller, we do not negotiate, and we do not handle any money relating to a property transaction. Our fee is charged for delivering a buyer's message; it is never contingent on a sale. This is relevant to your privacy because it means we collect only the limited data needed to deliver messages and operate the platform - not the extensive data an estate agency would gather.

This service is intended for adults aged 18 or over. It is not directed at children, and we do not knowingly collect personal data from anyone under 18.

We currently operate only in Northern Ireland, England and Wales. Scotland is outside our coverage and is excluded at the point a property is registered.

3. The personal data we collect

We aim to collect as little personal data as possible. What we collect depends on how you use the platform.

If you create an account (buyer or homeowner):

• Your email address (and, if you choose to use it in future, a mobile number). We use a passwordless sign-in system, so we do not store a password you have created.
• A randomly generated display name (for example, "SwiftOtter742"), which we assign automatically so you are not identified to other users by your real name.
• A record of your credit balance and credit transactions (purchases, refunds and adjustments).

If you send an offer letter (buyer):

• The property address and identifier (UPRN) you are sending the letter to.
• The offer amount you specify.
• The personal message you write to the homeowner. We store this in two forms: a redacted version (with certain contact details removed - see section 6) and the original, unredacted version you submitted.
• Payment information. Card payments are processed by Stripe; we do not see or store your full card details. We store a Stripe transaction reference for accounting and dispute-handling purposes.

If you claim and manage a property (homeowner):

• Confirmation that you control the email (or mobile) used to verify the claim.
• Property management settings you choose, such as a minimum offer ("floor price") and whether the property is currently accepting offers.

If you use the chat feature:

• The content of messages you send and receive through the platform.
• A record of whether messages have been read, and whether a conversation has been reported, suspended or ended.

Automatically:

• Limited technical information necessary to operate the site and keep it secure.
• A count of how many times a letter's claim link has been viewed, and when it was last viewed.

4. Why we use your data, and our lawful basis

Under UK data protection law, we must have a lawful basis for processing your personal data. The bases we rely on are set out below.

We do not use your personal data for marketing, and we do not sell your personal data to anyone.

5. Who we share your data with

We use a small number of carefully chosen service providers ("processors") to operate the platform. Each receives only the data necessary for its function.

• Stripe (payments) - receives the information necessary to process your card payment. OpenAddress does not receive or store your full card number.
• STANNP (letter printing and postage) - receives the recipient property address and the contents of the letter (your personal message and a claim link/QR code) so that the physical letter can be printed and posted. STANNP does not receive the offer amount.
• Brevo (email delivery) - receives your email address and the content of transactional emails (such as verification codes and notifications) so that we can send them to you.
• Google (Gemini API) (automated message scanning and moderation) - see section 6 below.
• Ideal Postcodes and Google Maps (address lookup and mapping) - receive address and location queries to help identify and display properties.

We may also disclose personal data if we are legally required to do so, or to establish, exercise or defend legal claims.

6. Automated processing of your messages

To keep the platform safe, the content of messages is processed by an automated system before and during use. You should read this section carefully.

Pre-send scanning. When you write a personal message to accompany an offer, the text of that message is sent to Google's Gemini API to check for personal contact details and for prohibited content. The system may redact certain details (such as a phone number or email address) from the version of your message that is initially shown, or it may ask you to rewrite a message that breaches our rules.

Where this processing happens. This message content is processed by Google under its paid-tier API terms. Google's processing may take place outside the UK or EEA, and we cannot guarantee that this content is processed only within the UK or EEA. Where personal data is transferred outside the UK, we rely on the safeguards provided under the relevant provider's terms. By using the messaging feature, you understand that your message content is processed in this way.

Disclosure of your message on chat unlock. If a homeowner responds and a buyer pays to unlock the chat, the buyer's original, unredacted message - including any contact details the buyer chose to include in it - becomes visible to the homeowner inside the chat. If you are a buyer, do not include information in your message that you are not willing for the homeowner to see once the chat is unlocked.

Moderation of conversations. If a message is reported, an automated assessment (again using Google's Gemini API) helps us decide what action to take. A conversation may be suspended automatically pending review. You have the right to ask us to review any automated decision that significantly affects you; contact hello@openaddress.co.uk.

7. How long we keep your data

• Chat conversations are kept for approximately 13 months after the conversation becomes inactive (a retention period of 365 days plus a 30-day grace buffer), after which they are deleted.
• Account, offer and payment records are kept for as long as your account is active and for a reasonable period afterwards, to meet our accounting, audit, fraud-prevention and dispute-resolution obligations.
• Opt-out (suppression) records are kept indefinitely. This is deliberate: an opt-out record is how we ensure an address that has asked never to be contacted again is permanently excluded. Deleting it would defeat its purpose.

8. Your rights

Under UK data protection law you have the right to:

• access the personal data we hold about you;
• ask us to correct inaccurate data;
• ask us to delete your data in certain circumstances (note that we may need to retain some records for legal reasons, and that opt-out records are retained as described above);
• object to or restrict certain processing;
• request portability of data you have provided to us;
• where processing is based on consent, withdraw that consent; and
• ask us to review any automated decision that significantly affects you.

To exercise any of these rights, contact hello@openaddress.co.uk. We will respond within the timeframes required by law.

You also have the right to complain to the Information Commissioner's Office (the UK regulator) at ico.org.uk if you are unhappy with how we have handled your data, though we would appreciate the chance to put things right first.

9. Homeowners who receive a letter

If you have received a physical letter through OpenAddress, you did not give us your data directly - a buyer sent a letter to your property's address.

• We do not hold your name. The letter is addressed generically (for example, "The Homeowner").
• We hold the property address and identifier (UPRN) associated with the letter, and a record of how many times the claim link was viewed.
• You can opt out at any time, with no need to provide any personal details, by following the opt-out link associated with your letter. Opting out permanently suppresses your address so that no further letters can be sent to it through OpenAddress.
• You only provide an email or mobile number if you choose to start a conversation with the buyer. We use it solely to notify you about that conversation - never for marketing, and the buyer never sees it.

10. Security

We take reasonable technical and organisational measures to protect your personal data, including secure (encrypted) connections to the website and restricted access to personal data. No system can be guaranteed completely secure, but we work to protect your information and to limit the data we hold in the first place.

11. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top shows when it was last changed. If we make significant changes, we will take reasonable steps to bring them to your attention.

12. Contact

OpenAddress Ltd, Ground Floor, Gallery Building, 65-69 Dublin Road, Belfast, BT2 7HG.
Email: hello@openaddress.co.uk. ICO registration: ZC179457.