Artemis Origination Privacy Notice
Document control
- Controller: Artemis Property Services Ltd
- Company number: 16933084
- Registered office: 61 Bridge Street, Kington, HR5 3DJ, United Kingdom
- Contact: info@artemispropertyservices.com
- Notice ID: artemis.origination.privacy
- Applies to: Register Your Mandate, mandate administration, opportunity matching, Deal Room activity and related Artemis Origination communications.
- Also applies to: submitting an Opportunity and making an introduction through Artemis Origination.
1. Who we are
Artemis Property Services Ltd (Artemis, we, us) is responsible for the personal information described in this notice when it acts as controller.
This notice explains how we use personal information in connection with Artemis Origination, including when you register or maintain a mandate, receive or review opportunities, use a Deal Room, request evidence, respond to an opportunity or take part in an introduction.
2. Information we may collect
Depending on how you use Artemis Origination, we may collect:
- your name and contact details;
- your organisation, role and authority to act;
- mandate criteria and preferences;
- funding, timing, geography, strategy, transaction-size and asset-type information you choose to provide;
- communications with Artemis;
- records of opportunities sent to you and your responses;
- Deal Room access and activity records needed for security, confidentiality and audit;
- compliance information where identity, authority, sanctions, AML, source-of-funds or similar checks are required;
- technical and security information generated when you use our systems; and
- records showing which terms and notices were presented and accepted.
What we keep if you do not finish a form. Our origination forms run over several pages. The first page asks who you are and how to reach you. When you complete that page and move on, we keep what you entered on it, even if you then close the form without submitting it.
That record holds only the first page: your name, your contact details, your organisation or entity, your role or capacity, and how you would prefer to be contacted. What you tell us about an asset, a mandate, a situation, a price or a deadline is asked on later pages, is held only in your browser until you submit, and is not kept if you do not. There is nowhere in that record for it to be stored.
We keep the first page so that we can follow up with somebody who started and did not finish, and so that we can see whether our forms are difficult to complete. A record kept this way is not a submitted Mandate, Opportunity or introduction: it creates no Artemis obligation, is not acknowledged, and does not enter our origination queue.
Do not provide special-category, criminal-offence or other unusually sensitive personal information unless Artemis specifically asks for it through an appropriate process.
3. Why we use personal information
| Purpose | Proposed lawful basis |
|---|---|
| Register, maintain and operate your Mandate; respond to your requests; send mandate acknowledgements and relevant operational communications. | Taking steps at your request before entering a contract and/or performance of the mandate relationship. |
| Structure, assess and match Mandates with potentially relevant Opportunities. | Contract where necessary to provide the requested service; legitimate interests where we use proportionate internal analysis to operate and improve the origination service. |
| Manage Deal Room access, confidentiality controls, recipient-specific access and audit records. | Contract and legitimate interests in protecting confidential information, security and the integrity of our service. |
| Prevent fraud, misuse, unauthorised access and security incidents. | Legitimate interests and, where applicable, legal obligation. |
| Carry out identity, authority, sanctions, AML or similar checks where required. | Legal obligation and/or legitimate interests, depending on the particular check. |
| Maintain records for legal claims, audit, compliance and dispute resolution. | Legal obligation and legitimate interests in establishing, exercising or defending legal rights. |
| Contact somebody who completed the first page of an origination form and did not submit it, to ask whether they would like help finishing it, and understand where our forms are difficult to complete. | Legitimate interests in following up an enquiry a person had begun to make of us, and in operating and improving the origination service. This is not marketing: it concerns the specific enquiry that was started, and it stops on request. |
| Send optional marketing, market updates or newsletters, if Artemis offers them in future. Artemis does not currently send marketing to Artemis Origination users. | Consent where required by PECR/UK data-protection law, or legitimate interests only where the law allows it. Marketing choices are kept separate from the mandate service. |
4. How mandate and opportunity matching works
Artemis may use software and AI-assisted tools to structure information, compare a Mandate with Opportunities, calculate fit/coverage/confidence measures and help operators decide what to review next.
These tools assist the origination workflow. They do not, by themselves, enter you into a transaction, commit capital, make a legal agreement for you or create a similarly significant legal effect.
If Artemis later introduces solely automated decision-making that produces legal or similarly significant effects, this notice and the product controls must be reviewed before that processing begins.
5. Who we may share information with
We may share personal information where necessary with:
- Artemis personnel and authorised operators;
- service providers that host, secure, communicate, analyse or support Artemis systems;
- professional advisers such as lawyers, accountants or compliance advisers;
- owners, sellers, buyers, lenders, advisers, introducers or other counterparties where disclosure is necessary and permitted for a relevant Opportunity;
- law-enforcement bodies, courts, regulators or other authorities where required or permitted by law; and
- a purchaser or successor if the relevant Artemis business or assets are transferred, subject to appropriate protections.
We should use anonymised or limited information where that is sufficient.
Registering a Mandate does not by itself authorise unrestricted disclosure of your identity or contact information to counterparties.
Opportunity-specific confidentiality restrictions may further limit what can be disclosed.
6. Processors and international transfers
Some technology or service providers may process personal information on our behalf.
The providers Artemis Origination uses are:
- Supabase, which hosts our database and the map files used on our forms. Our database is located in London, United Kingdom.
- Vercel, which hosts our website and applications. Our application functions run in London, United Kingdom; website content is delivered through Vercel's global network.
- Resend, which sends our emails. Resend delivers our email through Amazon Web Services in Ireland.
- Microsoft, which provides the mailbox that receives emails you send to info@artemispropertyservices.com.
- Cloudflare, which provides Turnstile, a check that our forms are not being abused. It receives your IP address, browser details and interaction signals when you use an Artemis Origination form.
- Notion, which hosts the internal workspace Artemis uses to review Mandates, Buy Boxes, Opportunities and matches. It receives names and organisation names, Mandate titles and descriptions, and our assessment of them. It does not receive your email address, phone number or address.
Some of these providers are established in, or may access personal information from, countries outside the United Kingdom, including the United States.
Where personal information is transferred outside the United Kingdom, Artemis will use an appropriate lawful transfer mechanism where required.
7. How long we keep information
We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, including legal, regulatory, security and audit requirements.
- active Mandate data: while the Mandate is active and for the period reasonably needed to close or reconcile related activity;
- withdrawn Mandate data: withdrawal stops future sourcing and matching; operational detail no longer needed is deleted or anonymised, but records legitimately required for legal, compliance, audit or security purposes are kept for those purposes;
- agreement acceptances, agreement versions and material contractual and audit records: kept for the period reasonably needed to establish, exercise or defend legal rights, normally up to six years after the relevant relationship or transaction ends;
- the first page of a form that was never submitted: kept for a short period only — long enough to follow up once, and in any event no longer than six months from the day it was entered — then deleted, unless it became a submitted Mandate, Opportunity or introduction, in which case the rows above apply instead;
- security and technical logs: shorter, risk-based periods, unless an incident requires longer preservation; and
- marketing preferences: kept only as needed to honour opt-outs and demonstrate the applicable consent or objection history.
8. Your rights
Depending on the circumstances, you may have rights to:
- ask for access to your personal information;
- ask us to correct inaccurate information;
- ask us to erase information;
- ask us to restrict how information is used;
- object to certain processing;
- receive certain information in a portable form;
- withdraw consent where processing is based on consent; and
- object at any time to personal information being used for direct marketing.
These rights are not absolute in every circumstance.
To exercise a right, contact info@artemispropertyservices.com.
9. Marketing
Registering a Mandate does not require you to agree to general marketing.
Emails and messages that are necessary to acknowledge, administer or progress your Mandate or a relevant Opportunity are operational service communications.
Where Artemis sends optional marketing and consent is required, the marketing choice must be separate, specific and freely given. You can opt out of marketing at any time.
If you completed the first page of a form and did not submit it, a single message asking whether you would like help finishing it is a follow-up to the enquiry you had started, not marketing. Tell us you would rather not hear about it and we will not contact you again about it, and will delete what was kept.
Opting out of marketing does not withdraw an active Mandate or stop communications that are genuinely necessary to operate it.
10. Security and confidentiality
Artemis uses technical and organisational measures intended to protect personal information and confidential Deal Materials against unauthorised access, loss, misuse or disclosure.
Access should be limited according to role and need.
Deal Room links, recipient controls, audit events and other product security measures are part of this operating model, but no system can guarantee absolute security.
11. Keeping your information accurate
Please tell Artemis if important Mandate or contact information changes.
Artemis may ask you to reconfirm criteria where a Mandate becomes stale or where new information materially changes how it should be matched.
12. Complaints
If you have concerns about how Artemis uses personal information, contact us first at info@artemispropertyservices.com.
You also have the right to complain to the UK Information Commissioner's Office.
13. Changes to this notice
We may update this Privacy Notice.
Every published version should have a version number and publication date.
Where a change materially affects how an existing Mandate holder's personal information is used, Artemis should provide appropriate notice rather than silently replacing the historical record of what was shown.
This is version 1.0 of this document. It does not change: a revised document is published as a new version at its own address, and this version remains available here.