Privacy Policy & Collection Notice

1. Introduction

Danielou Pty Ltd trading as Elders Real Estate Wollongong (“we”, “us”, “our”) is committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy and Collection Notice explains:

• what personal information we collect and hold;
• how and why we collect, use and disclose personal information;
• how personal information is stored, protected, retained and destroyed;
• how individuals may access or correct their personal information or make a privacy complaint.

This Policy applies to all aspects of our real estate business, including sales, leasing, property management, inspections, open homes, auctions, and online interactions.

This Policy also explains how personal information may be collected, used and disclosed to comply with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations.

2. Collection Notice

When we collect personal information, we will inform you of:

• the identity and contact details of our business;
• the purpose of collection;
• whether collection is required or authorised by law;
• the consequences if information is not provided;
• how to access, correct or complain about handling of personal information; and
• whether information may be disclosed to third parties or overseas recipients.

3. What Personal Information We Collect

We collect only personal information that is reasonably necessary for our real estate business, including Property Management and Sales services.

Clients, property owners, buyers, tenants and prospective clients

• Full name
• Residential and postal address
• Email address and telephone numbers
• Date of birth
• Identification details, including driver’s licence, passport, proof of age card, company and trust documentation, beneficial ownership information and other documents required to verify identity and comply with AML/CTF obligations
• Financial information relevant to transactions, including rent payments, trust account payments and proof of income
• Rental history, references and employment details
• Property preferences and inspection history
• Information about pets, vehicles or co-occupants if relevant to tenancy
• Communications with us, including emails, phone calls and messages
• CCTV footage at our office premises, where applicable, for security and safety purposes only
• Offers, bids and negotiation history
• Property details and ownership information
• Company, trust and other entity information, including details of directors, trustees, officeholders, shareholders, beneficiaries and beneficial owners where required by law

Contractors and service providers

• Name and business details
• Contact details including postal address, phone number and email address
• Licensing and insurance details
• Bank account details for payment

Website and online interactions

• IP address, device and browser information, cookies and website analytics data
• Enquiry details submitted via online forms or website enquiries
• Marketing preferences

Sensitive information is only collected where required by law or with your consent.

Identification information is collected to verify identity, comply with legal obligations, and reduce fraud and security risks.

4. How We Collect Personal Information

We collect personal information:

• directly from you in person, by phone, email, online forms, QR codes, inspections, open homes and auctions;
• when you submit a rental application or tenancy agreement;
• when you inspect a rental property;
• when you submit a vendor or purchaser enquiry;
• when you provide documentation for property sales;
• from third parties with your consent or where authorised by law, such as referees, employers, tenancy databases and government agencies;
• from identity verification providers, government databases and other sources where required to comply with AML/CTF obligations;
• from publicly available sources where relevant and lawful.

5. When the Law Authorises or Requires Collection

Certain laws may require us to collect personal information, including:

• Property, Stock and Business Agents Act 2002 (NSW) and associated regulations;
• Residential Tenancies Act 2010 (NSW) and associated regulations;
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated Rules;
• other legal, regulatory or compliance obligations.

If required by law, we may collect, store and disclose your personal information without your consent.

Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Obligations

We may be required to collect, verify, use, store and disclose personal information and identification documents to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), associated Rules and regulatory requirements administered by AUSTRAC.

This may include collecting information to verify identity, determine beneficial ownership, undertake customer due diligence, assess risk, monitor transactions and comply with reporting obligations.

6. Why We Collect, Hold, Use and Disclose Personal Information

We collect, hold, use and disclose personal information where reasonably necessary to:

• provide real estate agency services, including sales, leasing and property management;
• conduct inspections, open homes and auctions;
• process tenancy applications and manage residential or commercial tenancies;
• manage property sales and purchases;
• comply with legal and regulatory obligations, including trust accounting and record-keeping;
• comply with AML/CTF obligations, including customer due diligence, identity verification, beneficial ownership checks, ongoing monitoring and reporting requirements;
• communicate with clients, buyers, sellers, landlords and tenants;
• maintain client and contact databases;
• manage payments, invoices and trust account transactions;
• handle complaints and disputes;
• improve our services and customer experience.

7. How Your Personal Information May Be Used

Property Management

• To identify and verify landlords, tenants and applicants
• To process rental applications and manage tenancies
• To advertise, market and promote properties
• To liaise with landlords, tenants, contractors and service providers
• To comply with legal or regulatory obligations

Sales

• To identify and verify vendors, purchasers and prospective buyers
• To negotiate and manage property sales
• To advertise and market properties
• To liaise with agents, contractors and advisors
• To comply with legal obligations

Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF)

• Verify your identity
• Verify ownership or control of companies, trusts and other entities
• Conduct customer due diligence and risk assessments
• Comply with AML/CTF legislation and AUSTRAC requirements
• Undertake ongoing monitoring where required by law
• Meet legal reporting and record-keeping obligations

Failure to provide information required for AML/CTF compliance may prevent us from providing certain services or proceeding with a transaction.

8. Disclosure of Personal Information

We may disclose personal information to:

• property owners, buyers, tenants and prospective parties involved in a transaction;
• other agents involved in property sales or management;
• auctioneers, valuers, insurers and mortgage providers;
• legal, financial or professional representatives;
• service providers and contractors, including trades, IT providers, software and marketing platforms;
• identity verification providers and compliance service providers engaged to assist us in meeting AML/CTF obligations;
• banks, insurers and professional advisers;
• government agencies, regulators or courts where required or authorised by law;
• tenancy databases such as TICA, where applicable and lawful;
• related entities within the Elders group where reasonably necessary for business operations;
• AUSTRAC, law enforcement agencies, government departments, regulatory bodies or other persons where disclosure is required or authorised under AML/CTF legislation.

We do not sell or trade personal information and only disclose information that is reasonably necessary for the relevant purpose.

9. Overseas Disclosure

Personal information is not generally disclosed to overseas recipients. However, we may use cloud-based software or service providers whose servers are located outside Australia, such as customer relationship management systems, email platforms or data storage providers.

Where this occurs, we take reasonable steps to ensure overseas recipients handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Certain identity verification or compliance service providers may store or process information outside Australia. We take reasonable steps to ensure any overseas recipient handles personal information in accordance with applicable privacy laws.

10. Direct Marketing and Opt-Out

We may use personal information, excluding sensitive information, to provide information about properties or services that may be of interest to you. This may include marketing and research related to our services.

You may opt out at any time by notifying us in writing or using the unsubscribe option in electronic communications. We will process your request as soon as reasonably practicable.

Direct marketing communications will be sent in accordance with the Spam Act 2003 (Cth).

11. Anonymity and Pseudonymity

Where lawful and practicable, individuals may interact with us anonymously or using a pseudonym.

Due to the nature of real estate transactions, inspections, auctions and tenancy applications, we are generally unable to deal with individuals who do not identify themselves, as identification is required for security, legal and contractual reasons.

12. Storage and Security

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

• secure electronic systems and password protection;
• restricted staff access on a need-to-know basis;
• locked physical files;
• staff privacy training.

13. Retention, Destruction and De-Identification

We retain personal information only for as long as necessary to meet business, legal and regulatory requirements. Certain records may be retained for longer periods where required under trust accounting, taxation, property agency or AML/CTF legislation.

When personal information is no longer required, it is securely destroyed or permanently de-identified so individuals cannot be reasonably identified.

Certain AML/CTF records may be retained for the periods prescribed by applicable legislation and regulatory requirements.

14. Data Breaches

In the event of a suspected or actual data breach, we will assess the incident and, where required, comply with the Notifiable Data Breaches scheme, including notifying affected individuals and the OAIC.

15. Access and Correction

You may request access to personal information we hold about you or request correction if it is inaccurate, incomplete or out-of-date.

Requests should be directed to:

Privacy Officer: Lou Niceski
Phone: (02) 4228 7878
Email: info@elderswollongong.com
Address: 353 Crown Street, Wollongong NSW 2500

We will respond within a reasonable timeframe in accordance with the Privacy Act.

16. Complaints

If you believe we have breached the Australian Privacy Principles, you may lodge a complaint with us. We will acknowledge your complaint, investigate promptly and respond in writing with the outcome.

We aim to respond to privacy complaints within 30 days.

If unresolved or you are not satisfied, complaints may be escalated to the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

17. Automated Decision-Making and AI

We do not use automated decision-making systems or artificial intelligence tools to make decisions about individuals.

All decisions relating to sales, leasing and property management are made by our staff.

18. Staff Awareness and Implementation

This Privacy Policy is actively implemented through staff training, day-to-day compliance, regular review of privacy practices, and availability of the Policy in-office, online and at collection points.

19. AML/CTF Collection Notice

From 1 July 2026, Australian real estate agencies are required to comply with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws.

We may collect personal information and identification documents from clients, purchasers, vendors, landlords, tenants and other parties to verify identity, understand ownership structures, identify beneficial owners, assess risk and comply with legal obligations.

Information collected for AML/CTF purposes may be disclosed to AUSTRAC, law enforcement agencies, government authorities and other persons where required or authorised by law.

Failure to provide requested information may prevent us from providing certain services or proceeding with a transaction.

20. Updates to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, regulatory obligations, business practices, technology, or Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) requirements.

This Policy will be reviewed periodically to ensure it remains current and compliant.

The most current version is always available on our website or upon request.

21. Contact Us

Privacy Officer: Lou Niceski
Danielou Pty Ltd – Elders Real Estate Wollongong
ABN: 19 091 294 530
Phone: (02) 4228 7878
Email: info@elderswollongong.com
Address: 353 Crown Street, Wollongong NSW 2500