1. Who We Are

Gregory Property Agents (ABN 90 574 086 449) is a licensed real estate agency operating under the Property and Stock Agents Act 2002 (NSW), Licence Number 20435105. Our principal place of business is:

We are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), as well as our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

2. What Personal Information We Collect

We collect personal information that is reasonably necessary to provide our real estate services. This may include:

• Identity information: Full name, date of birth, residential address, email address, phone number
• Identity documents: Passport, driver’s licence, or other government-issued ID (required for AML/CTF compliance)
• Financial information: Bank account details, rental payment history, trust account records
• Property information: Property address, ownership details, tenancy history, inspection records
• Transaction information: Sale/purchase details, lease agreements, agency agreements
• Marketing preferences: Communication preferences, property search criteria
• Website data: IP address, browser type, pages visited (via cookies — see Section 11)

3. How We Collect Your Information

We collect personal information in the following ways:

• Directly from you — via agency agreements, tenancy applications, contact forms, phone, email or in person
• From third parties — including other real estate agents, referrers, tenancy databases, PEXA, and government registries
• From publicly available sources — including NSW Land Registry Services and ASIC
• Automatically — via our website (gregory.agency) through cookies and analytics tools

Where practicable, we will collect personal information directly from you. If we collect information about you from a third party, we will take reasonable steps to notify you.

4. How We Use Your Information

We use your personal information for the following purposes:

• Providing real estate sales, property management and leasing services
• Verifying your identity as required under the AML/CTF Act 2006
• Processing rental applications and managing tenancy agreements
• Managing trust account transactions and financial records
• Communicating with you about properties, listings and services
• Sending marketing communications (with your consent — see Section 12)
• Complying with our legal and regulatory obligations
• Resolving complaints and disputes

5. Disclosure of Your Information

We may disclose your personal information to the following parties where necessary:

Recipient	Purpose
AUSTRAC	AML/CTF reporting obligations, including Suspicious Matter Reports (SMRs)
NSW Fair Trading	Licensing, compliance and regulatory requirements
External auditors	Trust account auditing (Number Solutions Tax & Accounting)
Commonwealth Bank of Australia	Trust account management
NSW Rental Bonds Online (RBO)	Bond lodgement and management
Property listing portals	Domain, realestate.com.au — property marketing
Professional indemnity insurer	Berkley Insurance Australia — claims and notifications
Legal advisors	Where required for dispute resolution or legal compliance

6. Overseas Disclosure

Some of the third-party platforms we use to store and manage your information are cloud-based services that may store data on servers located outside of Australia. These include:

Platform	Purpose	Likely Overseas Location
Google Workspace	Email, document and file storage	United States
HubSpot	CRM and client relationship management	United States
Property Tree	Property management and trust accounting	Australia (primary)

In accordance with APP 8, before disclosing your personal information to an overseas recipient, we take reasonable steps to ensure the recipient does not breach the APPs in relation to that information. By engaging our services, you consent to the storage and processing of your information on these platforms in accordance with their respective privacy policies.

7. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legal obligations:

Record Type	Retention Period
AML/CTF records (identity verification, CDD)	7 years
Agency agreements and contracts	7 years
Trust accounting records	7 years
Audit records	7 years
Client intake and onboarding records	7 years
Marketing and communication records	3 years

After the applicable retention period, personal information will be securely destroyed or de-identified.

8. Security

We take the security of your personal information seriously. Our security measures include:

• Multi-factor authentication (MFA/2FA) on all platforms used to store or access personal information
• Password management via 1Password and Google Password Manager
• Restricted staff access — personal information is accessible only to authorised personnel on a need-to-know basis
• Cloud-based storage with provider-managed security (Google Workspace, Property Tree, HubSpot)
• No cash transactions — all financial transactions are conducted via secure electronic means

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

9. Access and Correction

You have the right to request access to the personal information we hold about you, and to request corrections if the information is inaccurate, incomplete or out of date.

To make an access or correction request, please contact us using the details in Section 10. We will respond to your request within a reasonable timeframe (generally within 30 days). In some circumstances, we may be required by law to refuse access — if this occurs, we will provide written reasons.

10. Privacy Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us in the first instance:

We will acknowledge your complaint within 3 business days and aim to resolve it within 10 business days. If you are not satisfied with our response, you may escalate your complaint to the:

• Office of the Australian Information Commissioner (OAIC)
  Website: www.oaic.gov.au
  Phone: 1300 363 992
• NSW Fair Trading (for matters relating to real estate agency conduct)
  Website: www.fairtrading.nsw.gov.au
  Phone: 13 32 20

11. Cookies & Website Analytics

Our website (gregory.agency) may use cookies and similar tracking technologies to improve your browsing experience and analyse website traffic. Cookies are small data files stored on your device.

We may use:

• Essential cookies — required for the website to function correctly
• Analytics cookies — to understand how visitors use our website (e.g. Google Analytics)

You can control or disable cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website. By continuing to use our website, you consent to our use of cookies in accordance with this policy.

12. Marketing Communications

We may send you marketing communications about our services, new listings and property market updates. We will only send marketing communications where you have provided your consent, or where permitted by law.

You may opt out of receiving marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email
• Contacting us directly at bj@gregory.agency

We comply with the Spam Act 2003 (Cth) in all electronic marketing communications.

13. Updates to This Policy

We review this Privacy Policy annually as part of our compliance review cycle (June each year), or sooner if required by changes to legislation or our business operations. The current version of this policy is always available on our website at gregory.agency.

The effective date of the current version is shown at the top of this document. We encourage you to review this policy periodically.