1. Who We Are (Data Controller)

Business Name: Eighth Heaven Sourcing Ltd
Registered Office: [Address available on request or via Companies House]
Data Protection Officer (DPO): Yuriy Boykov
Email: info@eighthheavensourcing.com
Phone: +44 7341 699667
ICO Registration: ✅ Registered with the Information Commissioner’s Office

2. What Personal Data We Collect

Depending on your relationship with us (client, seller, investor, or site visitor), we may collect:

• Full name
• Date of birth
• Email address
• Phone number
• Home address
• Proof of ID (e.g. passport or driving licence)
• Proof of address (e.g. utility bill <3 months old)
• Bank account details (if required for payment/funding proof)
• Nationality, source of funds, and legal right to act on property (if applicable)

3. How We Collect Your Data

We collect data when:

• You fill out a form on our website
• You communicate with us via email, phone, or in person
• You are onboarded as a seller or investor
• We carry out due diligence in line with AML laws
• You interact with our third-party platforms (e.g., Zeevou, Calendly, Xero)

4. Why We Use Your Data

We use your personal data to:

• Respond to your enquiries
• Offer and manage property sourcing services
• Perform identity verification and due diligence (AML compliance)
• Maintain business and regulatory records
• Process payments or commissions
• Send occasional marketing (if opted-in)

5. Our Legal Grounds for Using Your Data

We process your data under these legal bases:

• Consent – When you agree to receive marketing or submit forms
• Contract – To fulfil a service or offer
• Legal Obligation – To comply with HMRC, AML, or regulatory requirements
• Legitimate Interests – To manage and improve our business

6. Who We Share Your Data With

We may share your data with:

• Identity check providers (e.g. Credas, Etsos)
• Solicitors, estate agents, financial or legal advisors
• Technology platforms (e.g. Zeevou, Stripe, Calendly, Google Workspace)
• HMRC or regulatory authorities (e.g. NCA in case of suspicious activity)

We do not sell or rent your data to anyone.

7. Data Retention

We only keep personal data for as long as necessary:

• AML/client records: 5 years after the business relationship ends
• Website enquiries: deleted within 12 months if no ongoing engagement
• Email correspondence: reviewed annually and deleted where no longer required

8. Your Data Protection Rights

You have the right to:

• Access your personal data
• Request correction or erasure
• Withdraw consent at any time
• Object to or restrict processing
• Request a copy of your data (data portability)
• Lodge a complaint with the ICO: www.ico.org.uk

9. Data Security

We take appropriate security measures:

• Encrypted storage (Google Drive, Dropbox)
• Password-protected systems
• Staff training
• Secure shredding for physical files
• Locked cabinets and secure transfer protocols

10. Cookies and Website Tracking

We may use cookies for site analytics or basic functionality. You can disable cookies via your browser.

Our website may include links to third-party sites. We are not responsible for their privacy policies.

11. Contacting Us

If you have questions or concerns about your data:

Email: info@eighthheavensourcing.com
Phone: +44 7341 699667

12. Accessing Our Full Privacy Policy

For full regulatory detail, you may:

• 📎 Download the Full Data Privacy Policy (PDF)
• 📩 Or email us at info@eighthheavensourcing.com to request a copy