Privacy Policy

1. Our commitment to privacy

Truswell Project Partners Pty Ltd (TPP, we, us or our) respects your privacy and is committed to protecting the personal information entrusted to us.

We handle personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

As a real estate business, we are also required to collect, verify, use, retain and, in some circumstances, disclose information to comply with our obligations under Australian anti-money laundering and counter-terrorism financing laws.

This Privacy Policy explains how we collect, hold, use and disclose personal information and how you can access or correct your information or make a privacy complaint.

2. Personal information we collect

The information we collect depends on your relationship and dealings with TPP.

It may include:

• your name, address, telephone number and email address;
• your date of birth;
• information provided through website enquiries, telephone calls, emails, inspections and sales enquiries;
• information about your property requirements, preferences and purchasing intentions;
• details relating to the purchase or sale of real estate;
• expressions of interest, reservations, contracts and other transaction documents;
• financial or finance-related information relevant to a property transaction;
• details of your mortgage broker, lender, conveyancer, solicitor, builder or other professional representatives;
• correspondence and records of communications with you;
• identification information and documents where required or permitted by law;
• information concerning companies, trusts, partnerships and other entities;
• information about directors, trustees, beneficial owners, representatives or other persons associated with a customer;
• information required to undertake customer due diligence, identity verification, risk assessment, monitoring, reporting and record keeping under AML/CTF laws; and
• other information that you provide to us or that we are authorised or required by law to collect.

We will only collect sensitive information where it is reasonably necessary for our functions or activities and we have your consent, or where its collection is otherwise permitted or required by law.

3. How we collect information

We generally collect personal information directly from you.

This may occur when you:

• contact us or submit an enquiry;
• use our website;
• visit a sales office or development;
• register your interest in a property or development;
• complete an expression of interest, reservation, contract or other document;
• communicate with us by telephone, email, online form or in person;
• participate in a property transaction; or
• complete identity verification or customer due diligence requirements.

We may also collect personal information from third parties where appropriate or permitted by law, including:

• property developers and vendors we represent;
• conveyancers and solicitors;
• mortgage brokers, lenders and finance professionals;
• builders;
• identity verification and AML/CTF service providers;
• government agencies, regulators and public registers;
• technology and information service providers; and
• other persons involved in a property transaction.

Where reasonable and practicable, we will collect personal information directly from you.

4. Why we collect and use personal information

We may collect, hold, use and disclose personal information for purposes including:

• responding to enquiries;
• providing real estate and project sales services;
• assisting with property purchases and sales;
• managing expressions of interest, reservations and contracts;
• communicating with prospective purchasers and purchasers;
• communicating with developers and vendors we represent;
• coordinating contract, conveyancing, finance and settlement processes;
• maintaining purchaser, prospect and sales records;
• administering our customer relationships and business;
• improving our services;
• communicating information about developments, land releases and property opportunities;
• verifying identity;
• undertaking customer due diligence;
• assessing and managing money laundering, terrorism financing and proliferation financing risks;
• complying with AML/CTF reporting and record-keeping requirements;
• preventing or detecting fraud, misuse or unlawful activity;
• complying with legal and regulatory requirements; and
• establishing, exercising or defending legal rights.

We generally use or disclose personal information for the purpose for which it was collected, for a related purpose that you would reasonably expect, with your consent, or where otherwise permitted or required by law.

5. AML/CTF and identity verification

Australian anti-money laundering and counter-terrorism financing laws apply to certain services provided by real estate professionals.

Where these requirements apply, TPP may be required to:

• identify and verify customers and certain associated persons;
• identify beneficial owners;
• understand the nature and purpose of a customer relationship or transaction;
• assess customer risk;
• conduct ongoing or enhanced customer due diligence;
• monitor transactions or customer relationships;
• retain prescribed records; and
• make reports to AUSTRAC.

We use specialist technology and service providers, including an AML/KYC platform, to assist us in meeting these obligations.

Information may be disclosed to AUSTRAC, law enforcement agencies, regulators or other government authorities where required or authorised by law.

Certain laws may restrict our ability to tell you about particular reports, assessments or disclosures.

6. Technology and service providers

TPP uses third-party technology and professional service providers to operate our business and deliver our services.

These may include providers of:

• customer relationship management systems;
• property contract and transaction management systems;
• electronic documentation and signing services;
• conveyancing and property documentation services;
• email and productivity systems;
• cloud storage and hosting;
• website hosting and website analytics;
• identity verification and AML/CTF services;
• artificial intelligence tools;
• IT and cybersecurity services; and
• professional advisory services.

Personal information may be provided to these services where reasonably necessary for the purposes described in this Privacy Policy.

TPP currently uses technology including Brightfox CRM, Greatforms/Eckermann Property Forms, Microsoft 365 and Outlook, Squarespace, business AI services and specialist AML/KYC technology.

Our systems and service providers may change from time to time.

7. Use of artificial intelligence

TPP may use business-grade artificial intelligence and technology tools to assist with administrative, research, drafting, summarisation, analysis and business-support activities.

Where personal information is processed using an AI service, we take reasonable steps to limit the information provided to what is reasonably necessary for the relevant task and to use appropriate business-grade services and security settings.

We currently use business AI services including ChatGPT and Claude.

AI tools are used to assist our team rather than replace appropriate human judgement.

Material decisions concerning property transactions, contractual matters, purchaser relationships or AML/CTF obligations remain subject to appropriate human oversight and applicable legal requirements.

8. Disclosure of personal information

Depending on the circumstances, we may disclose personal information to:

• developers and vendors we represent;
• conveyancers and solicitors;
• mortgage brokers, lenders and finance professionals;
• builders;
• persons authorised to act on your behalf;
• parties involved in a property transaction;
• identity verification and AML/CTF service providers;
• CRM, document management, electronic signing, email, cloud, website and technology providers;
• professional advisers, insurers, auditors and consultants;
• AUSTRAC and other government bodies, regulators or law enforcement agencies where required or authorised by law; and
• other persons where you have authorised the disclosure or where it is otherwise permitted or required by law.

TPP does not sell personal information.

9. Overseas processing and disclosure

Some of the technology and service providers used by TPP operate internationally.

As a result, personal information may be processed, stored or accessed outside Australia, including in the United States and other countries in which our technology and cloud service providers or their subprocessors operate.

Where we disclose personal information to an overseas recipient, we will take reasonable steps to handle the disclosure in accordance with applicable Australian privacy law.

Because cloud and technology providers may change their infrastructure and subprocessor locations from time to time, further information about the locations relevant to a particular service can be requested from our Privacy Officer.

10. Our website, cookies and analytics

Our website is hosted using Squarespace.

When you visit our website, certain technical information may be collected automatically, including information such as your IP address, browser or device information, pages visited and information about how you interact with the website.

Our website may use cookies and similar technologies that are necessary for the website to operate or that help us understand website usage and improve our services.

Where required or appropriate, visitors will be provided with options to manage non-essential cookies.

Information submitted through a website enquiry or contact form may be provided to TPP and processed by our website and technology providers.

You can manage cookies through your browser settings and, where available, through the cookie controls provided on our website.

Our website may contain links to websites operated by third parties, including developers whose projects we represent. Those websites have their own privacy practices and policies, and TPP is not responsible for how third-party websites handle personal information.

11. Direct marketing

Where permitted by law, we may use your contact information to communicate with you about developments, land releases, property opportunities or TPP services that we believe may be relevant to you.

You can ask us to stop sending direct marketing communications at any time by:

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

We will take reasonable steps to action your request.

12. How we protect personal information

Personal information may be held electronically or, where necessary, in physical records.

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

Measures may include:

• password protection and access controls;
• secure business systems;
• limiting access to information to people who require it;
• using reputable technology and cloud service providers;
• maintaining appropriate business and cybersecurity practices; and
• reviewing how sensitive and identification information is handled.

No electronic system or method of transmission can be guaranteed to be completely secure. Where we become aware of a suspected data breach, we will assess and respond to it in accordance with applicable Australian law.

13. Retention and destruction

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and to meet our legal, regulatory, contractual and business obligations.

Certain records must be retained for periods prescribed by law, including records required under AML/CTF legislation.

When personal information is no longer required and we are not legally required or authorised to retain it, we will take reasonable steps to destroy or de-identify it.

14. Accessing and correcting your information

You may request access to personal information we hold about you.

You may also ask us to correct information if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

Please contact our Privacy Officer using the details below.

We may need to verify your identity before providing access to information or making a correction.

In some circumstances, Australian law permits or requires us to refuse access to particular information. Where this occurs, we will generally explain the reason for the refusal where we are legally permitted to do so.

15. Anonymity and pseudonyms

Where it is lawful and practicable, you may interact with us anonymously or using a pseudonym.

However, we will generally need to know your identity where you enter into or are involved in a property transaction, where identification is reasonably necessary for us to provide our services, or where Australian law requires us to identify or verify you.

16. Privacy complaints

If you believe we have not handled your personal information appropriately or have breached your privacy rights, please contact our Privacy Officer.

Please provide enough information for us to understand and investigate your concern.

We will take your complaint seriously and aim to acknowledge and investigate it within a reasonable period.

If you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

17. Data breaches

TPP maintains processes for responding to suspected or actual data breaches.

Where a data breach meets the requirements of Australia's Notifiable Data Breaches scheme, we will take the steps required by law, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, technology, information-handling practices or legal obligations.

The current version will be published on our website and will identify the date it was last updated.

19. Contact us

For questions, requests or complaints concerning privacy or the way TPP handles personal information, please contact: