Privacy Policy

This Privacy Policy explains how Tom Pellegrini & Partners Pty Ltd ("TP&P", "we", "us", "our"), ABN 76 661 152 450, ACN 661 152 450, collects, holds, uses and discloses personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles ("APPs").

This Policy applies to personal information handled in connection with our real estate, strategic property, property-related investment, development, relocation and related advisory and business activities.

Some TP&P activities may involve designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ("AML/CTF Act"). Where applicable, additional requirements may apply to the collection, verification, use, disclosure and retention of personal information.

Not all enquiries, advisory activities, professional collaborations or property-related services require customer due diligence under the AML/CTF Act.

We may collect personal information reasonably necessary for our functions and activities, including:

• name, address, contact details and date of birth;
• identification information and, where necessary for verification, identification documents;
• employment, business and company information;
• property ownership, requirements, preferences and interests;
• financial and investment information;
• leasing or tenancy information;
• beneficial ownership and control information;
• information about persons authorised to act for, represent or control a customer or organisation;
• source-of-funds and source-of-wealth information where required;
• tax identification numbers or equivalent government identifiers where relevant;
• information collected or generated through identity verification, customer due diligence and relevant politically exposed person ("PEP"), sanctions or adverse-media screening;
• professional credentials, licensing, authorisations, memberships, insurance and regulatory-standing information;
• information submitted through professional collaboration or counterparty due-diligence processes;
• records of communications and interactions with us;
• marketing preferences;
• limited technical and website usage information; and
• other information you provide to us or that we otherwise lawfully collect.

Where lawful and reasonably necessary, we may also collect sensitive information with consent or where collection is otherwise required or authorised by law.

Some information used in connection with lawful AML/CTF screening may constitute sensitive information under the Privacy Act 1988 (Cth), including political-association or criminal-record information.

We may collect personal information directly from you when you contact us, use our website, attend a meeting or inspection, submit an enquiry or Expression of Interest, complete a form, enter into an engagement or otherwise deal with us.

Where lawful and appropriate, we may also collect information from:

• property owners, buyers, sellers, landlords or tenants;
• referral sources and business contacts;
• professional advisers;
• publicly available records and property platforms;
• government, regulatory, corporate-registry or sanctions sources;
• identity-verification and AML/CTF screening providers; and
• service providers assisting our business operations.

We may collect, hold and use personal information to:

• respond to enquiries and understand your requirements;
• provide or facilitate real estate, strategic property, development, relocation and related advisory services;
• facilitate property sales, acquisitions and related transactions;
• arrange meetings, consultations and inspections;
• manage client, contractual, professional and business relationships;
• communicate relevant property, market or development opportunities;
• provide marketing communications where permitted by law;
• verify identity and undertake legitimate preliminary professional, commercial or counterparty due diligence, including where appropriate checks concerning ownership or control, professional or regulatory standing, sanctions exposure and adverse media;
• assess potential professional, referral, supplier or commercial relationships;
• where applicable, conduct customer due diligence, identity and beneficial-ownership verification, relevant screening and risk assessment required for AML/CTF compliance;
• administer and improve our business and services;
• comply with legal and regulatory obligations; and
• manage complaints or disputes.

Preliminary professional or commercial due diligence is separate from customer due diligence under the AML/CTF Act unless the circumstances independently require statutory customer due diligence.

We may disclose personal information where reasonably necessary to:

• employees, contractors, consultants and authorised representatives;
• persons relevant to an enquiry, service or property transaction;
• professional advisers, consultants and specialists;
• technology, administration and other service providers;
• identity-verification and AML/CTF screening providers;
• AUSTRAC and other government, regulatory, court or law-enforcement authorities where disclosure is required or authorised by law; and
• other persons where disclosure is required or authorised by law.

We do not sell personal information to third parties.

TP&P operates independently while also working, where appropriate, with Prestige by Harcourts Property Centre and other Harcourts network participants in connection with certain real estate, transaction, referral, office-support and client-service matters.

Where relevant to a matter, personal information may be disclosed to one of those entities where reasonably necessary or appropriate. Disclosure is not automatic.

Where another entity separately collects or receives personal information, it may handle that information in accordance with its own privacy policy and legal obligations.

Where AML/CTF obligations apply, responsibility depends on the legal entity providing the relevant designated service and the circumstances of the matter. Disclosure between entities does not of itself transfer responsibility for those obligations or mean that one entity’s compliance requirements have been satisfied by another.

We may send property alerts, market updates, insights, invitations and information about our services or opportunities where permitted by law.

You may opt out at any time by:

• using the unsubscribe facility in an electronic communication; or
• contacting us.

We comply with the Spam Act 2003 (Cth) and other applicable marketing laws.

When you use our website, we may collect limited technical and usage information through our website platform to operate, secure and understand use of the site. We may also use a functional browser setting or cookie to remember interface preferences.

We may use customer-management, mapping, scheduling and other technology-assisted tools to support our administration, communications, research and business operations.

Where applicable, technology may also assist with identity verification and AML/CTF screening. Technology-assisted checks support, but do not replace, TP&P’s compliance judgments and decisions.

Our primary customer and compliance systems use third-party technology services and are currently hosted in the United States.

Other service providers may also store or process personal information outside Australia.

Where personal information is likely to be disclosed to an overseas recipient, we take reasonable steps as required by Australian privacy law and, where practicable, identify the relevant countries.

Some address-search or other technology services may involve overseas processing or disclosure. Further information may be provided in an applicable Privacy Collection Notice.

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

Access is limited to persons who require the information for legitimate business or compliance purposes, having regard to its nature and sensitivity.

No method of electronic transmission or storage is completely secure.

If we become aware of a data breach involving personal information, we will assess and respond to it in accordance with applicable law.

Where required under the Privacy Act 1988 (Cth) and the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner ("OAIC").

You may request access to personal information we hold about you or request correction where appropriate, subject to applicable legal exceptions.

In some circumstances, Australian law may restrict the information we are permitted to provide, including under applicable AML/CTF secrecy, confidentiality or tipping-off provisions.

Where access or correction is refused, we will provide reasons to the extent required and permitted by law.

We retain personal information for as long as reasonably necessary for our business, legal, regulatory and compliance purposes.

AML/CTF records are retained for the periods required by applicable law.

Where an identity document has been collected solely for verification, our approach is to minimise retention of the complete document and, where practicable, retain the required identification and verification record instead.

When personal information is no longer required or authorised to be retained, we take reasonable steps to securely destroy or de-identify it.

If you believe we have mishandled your personal information or breached applicable privacy law, you may contact us using the details below.

We will investigate privacy complaints and aim to respond within a reasonable period, generally within 30 days where practicable.

If you are not satisfied with our response, you may contact the OAIC at www.oaic.gov.au.

We may update this Privacy Policy to reflect changes in law, our services or our personal-information handling practices.

The current version will be available on our website.

For privacy enquiries, access or correction requests or complaints, please contact:

Privacy Officer

Tom Pellegrini & Partners Pty Ltd

Email: tom@tompellegriniandpartners.com.au

Phone: +61 477 546 168

Address: c/o Prestige by Harcourts Property Centre, 15 Malt Street, Fortitude Valley, QLD 4006