Privacy Policy.

1. Introduction

This Privacy Policy explains how TOM collects, uses, stores, and shares personal data when you use our UK property investment platform. We process data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data we collect

Depending on how you use TOM, we may process:

• Account data: name, email, phone number, role (e.g. buyer, seller), and authentication details.
• Usage data: device type, browser, approximate location, pages viewed, and interactions with listings and notifications.
• Deal & messaging data:information you submit about properties, enquiries, and messages sent through the platform.

3. Purposes & lawful bases

We use personal data to:

• Provide, secure, and improve our services (contract & legitimate interests).
• Send service and security communications (contract & legal obligation).
• Send marketing where you have consented or where soft opt-in applies under UK law; you can opt out at any time.
• Meet legal, regulatory, and accounting requirements.

4. Sharing & processors

We may share data with trusted service providers (e.g. hosting, email, analytics, payment) under strict agreements, and with professional advisers where required. We do not sell your personal data. We may disclose information if required by law or to protect rights and safety.

5. International transfers

Where data is processed outside the UK, we ensure appropriate safeguards (such as UK-approved standard contractual clauses) are in place.

6. Retention

We keep data only as long as needed for the purposes above, including legal, tax, and dispute resolution periods, then delete or anonymise it.

7. Your rights

Under UK GDPR you may have the right to:

• Access, rectify, or erase your personal data.
• Restrict or object to certain processing.
• Data portability where applicable.
• Withdraw consent where processing is consent-based.
• Lodge a complaint with the ICO (www.ico.org.uk).

8. Cookies & similar technologies

We use a small number of cookies, listed below. Necessary cookies always run; the Stripe payments category only runs once you accept it in the cookie banner shown on your first visit, and is only ever set at the point you make a card payment.

9. Contact

For privacy requests or questions, use the contact options provided in the app or on our website. We will respond within a reasonable period in line with UK GDPR.