Privacy Policy

1. Our Commitment to Your Privacy

Active Property Investing Pty Ltd (“API”, “we”, “us” or “our”) is committed to protecting your personal information and handling it responsibly, transparently and securely.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information in accordance with:

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) (as amended in 2024); and
• The Property and Stock Agents Act 2002 (NSW), the Property and Stock Agents Regulation 2022 (NSW), and applicable rules of conduct for licensed real estate agents.

We aim to collect only what is necessary, use it only for its intended purpose, and keep it only for as long as required.

2. Who We Are and What We Do

API is a property marketing and buyer facilitation business. We are not a traditional residential real estate agency.

Our services include:

• Marketing and promoting properties on behalf of vendors;
• Assisting buyers through the reservation and contract preparation process; and
• Coordinating information between buyers, vendors and their legal representatives (such as solicitors or conveyancers).

We do not provide legal or financial advice, and contracts of sale are prepared and completed by qualified legal professionals.

3. The Personal Information We Collect

(a) General enquiries and early engagement

When you interact with us (including via our website enquiry forms), we may collect:

• Name;
• Email address;
• Phone number; and
• General information you choose to provide about your property interests or circumstances.

This information helps us understand how we may assist you.

(b) Client Questionnaire and consultation process

When you formally engage our services, we may collect personal information through our Client Questionnaire and consultation materials, including:

• Contact details;
• General personal and financial background information relevant to your property goals; and
• Preferences and requirements relating to property purchases.

This information is used only to provide and tailor our services, property research and recommendations.

(c) Reservation / Expression of Interest (EOI) Stage — Identity Verification and AML/CTF Requirements

We do not collect identity documents during the initial enquiry or consultation stages.

Identity document collection and verification are only undertaken when you submit a Reservation Form or Expression of Interest (EOI) to purchase a property and verification is required to progress towards the preparation of a Contract of Sale.

As an enrolled reporting entity under Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation, Active Property Investing Pty Ltd (API) is legally required to undertake Customer Due Diligence (CDD) before facilitating certain property transactions.

Accordingly, the personal information you provide as part of the Reservation or EOI process is collected and used to:

• verify your identity using the information provided and any supporting identification documents;
• verify beneficial owners where companies, trusts or other legal entities are involved;
• screen customers and beneficial owners against applicable sanctions lists and Politically Exposed Person (PEP) databases;
• undertake a customer risk assessment in accordance with AML/CTF legislation;
• determine whether Enhanced Customer Due Diligence (ECDD) is required; and
• comply with API’s legal obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act and any applicable AUSTRAC reporting requirements.

From 1 July 2026, additional information is required within our Reservation and EOI forms to enable us to meet these legislative obligations. Where necessary, we may request further information or documentation to verify your identity or satisfy our AML/CTF compliance requirements.

4. How We Use Your Information

We collect, use and disclose personal information only where it is reasonably necessary for our functions and activities, to provide our services, or where required or authorised by law.

We use personal information to:

• Respond to enquiries and provide requested information;
• Deliver our services and fulfil our contractual obligations;
• Assist vendors and their legal representatives in progressing property transactions;
• Verify identity where legally or commercially required;
• Communicate with you about your engagement with us; and
• Comply with applicable legal, regulatory and professional obligations.

We do not use personal information for purposes that are unrelated to the reason it was collected, unless you have consented or we are otherwise permitted or required to do so by law.

Where required to comply with applicable laws and regulations, including anti-money laundering and counter-terrorism financing (AML/CTF) obligations, we may disclose personal information to government authorities, regulatory bodies (including AUSTRAC) and trusted third-party identity verification service providers engaged by Active Property Investing to assist us in meeting our legal obligations.

We maintain strict confidentiality over identity verification and AML/CTF screening activities. Information obtained through these processes is handled in accordance with applicable privacy laws and is disclosed only where authorised or required by law.

5. Disclosure of Personal Information

We may disclose personal information only where necessary, including to:

• Vendors (in connection with a property transaction);
• Solicitors, conveyancers or other legal representatives involved in preparing or completing a contract of sale;
• Professional advisers, service providers or contractors who assist us in operating our business (subject to confidentiality obligations); and
• Regulatory authorities where required or authorised by law.

We do not sell personal information.

6. Identity Documents and Deletion Practices

We take a data minimisation approach to identity documents.

Identification is collected only for the purpose of verifying a buyer’s identity and assisting with the reservation and contract preparation process.

Where ID is provided to a vendor or solicitor for the purpose of securing a property with intent to purchase, it is done solely for that purpose.

Once the contract process has been completed, any identity documents held by us are securely deleted and permanently removed in accordance with our cyber security and data destruction protocols.

We do not retain identity documents longer than necessary.

7. Marketing Communications

If you submit an enquiry form on our website or otherwise provide your contact details, this confirms that you consent to receiving communications from our team relevant to our services.

You may:

• Unsubscribe from marketing or communications at any time; and
• Opt out using the unsubscribe option provided or by contacting us directly.

We respect your communication preferences.

8. How We Store and Protect Your Information

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure.

Our security measures include:

• Secure electronic systems;
• Role-based access controls;
• Cyber security measures; and
• Secure deletion or destruction of personal information when it is no longer required.

While we take reasonable steps to protect your information, no method of storing or transmitting data is completely secure.

Active Property Investing uses secure cloud-based systems and trusted third-party technology providers, including Microsoft 365, Google Workspace, Zoho CRM, Dropbox, Xero and DocuSign, to collect, store, process and manage personal information in connection with the services we provide.

Depending on the services used, personal information may be stored, processed or backed up in Australia or in other countries where these providers operate secure data centres or business operations. Personal information may also be accessed by authorised members of our team located in Australia and the Philippines for the purposes of providing our services, managing client relationships and supporting our business operations. Access is limited to authorised personnel and subject to confidentiality obligations and appropriate security controls.

Where personal information is disclosed to, stored by or accessed through overseas service providers or authorised personnel, we take reasonable steps to ensure it is handled in a manner consistent with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

9. Access, Correction and Complaints

You have the right to:

• Request access to the personal information we hold about you; and
• Request correction of any inaccurate, incomplete or outdated information.

If you have a concern or complaint about how we handle your personal information, please contact us using the details below. We will respond within a reasonable timeframe and take appropriate steps to address your concern.

10. Contact Us

Active Property Investing Pty Ltd

Email: team@activepropertyinvesting.com.au
Website: www.activepropertyinvesting.com.au

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, regulation or our practices. The current version will always be available on our website.