Privacy Collection Notice

Ledger & Lane Property Agents applies the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) as the standard for its handling of personal information and complies with applicable privacy requirements.

Our company collects various personal information from owners, vendors, purchasers, tenants, prospective tenants, landlords, prospective landlords and members of the public who contact us or attend our office, inspections or use our website. This may include name, contact details, financial information and other personal and sensitive information in order that we may provide our services efficiently. We take reasonable steps to ensure the accuracy of the information we collect and that it is relevant and up to date.

We may also collect personal information from third parties where reasonably necessary, including tenancy application platforms, referees, employers, property agents, contractors and service providers.

If you do not provide the requested personal information, we may not be able to provide our services or respond to your enquiry.

This information we collect may be used for the following reasons:

1. security reasons, including monitoring attendance at property inspections and protecting properties under our control

2. to send news, information about our activities and general promotional material which we believe may be useful to you

3. to allow us to write, call, email or text you regarding your enquiry, property inspection, tenancy application, property management services, properties for lease or other real estate services that may be relevant to you, or to keep you informed of developments in the real estate market

4. to enable us to give feedback to the vendor and/or landlord regarding interest in a property that you have inspected or enquired about.

5. to help us carry out the services we have contracted to provide by way of an agency agreement with our clients

6. to comply with our legal and regulatory obligations

7. the information is used for our internal business purposes and will only be disclosed to third parties where reasonably necessary to provide our real estate and property management services, where required or authorised by law, or as outlined in our Privacy Policy.

If you do not wish to be contacted as part of our normal follow up procedures or wish your information not to be used to send you promotional material, you may opt out at any time by notifying us or using any available unsubscribe facility.

All personal and sensitive information we collect is held electronically and/or in hard copy in a secure manner. It will only be used for the purposes noted above and will only be disclosed where reasonably necessary to provide our services, where required or authorised by law, or as outlined in our Privacy Policy. Some of our service providers may store or process your personal information on our behalf, including outside Australia.

You have the right to:

• Request access to the information collected about you,

• Request correction of the information if it is not accurate, up to date or complete.

• Request removal of your personal information from our records where permitted by law

A copy of our Privacy Policy is available at www.ledgerandlane.com.au/privacy-policy

If you want to obtain more information about our Privacy Policy, or view, correct or remove your information you may contact our Privacy Officer Melanie Poole

p: 02 8201 6060

e: info@ledgerandlane.com.au

Privacy Policy for Ledger & Lane Property Agents

Overview

The purpose of this policy is to ensure that Ledger & Lane Property Agents manages personal and sensitive information responsibly, transparently, and in accordance with applicable privacy requirements. Ledger & Lane applies the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) as the standard for its handling of personal information and complies with the Privacy Act where it applies. This policy outlines how personal information is collected, used, disclosed, stored, and protected by Ledger & Lane Property Agents.

This policy applies to all personal and sensitive information collected by Ledger & Lane Property Agents in relation to clients, customers, personnel, contractors, and other stakeholders. It covers all methods of information handling, including digital, physical, and verbal communications.

Ledger & Lane Property Agents is committed to protecting the privacy of individuals and ensuring the confidentiality, security, and integrity of personal and sensitive information. The agency will apply the Australian Privacy Principles as its privacy standard and comply with applicable privacy and other relevant legislation while fostering trust and transparency in all interactions.

Ledger & Lane Property Agents applies the 13 Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) as the overall framework for its privacy practices and complies with the Privacy Act where applicable. Ledger & Lane Property Agents has developed and implemented this APP Privacy Policy.

Applicable Legislation

This policy is designed to maintain requirements with additional jurisdictional requirements including:

• Privacy Act 1988 (Cth), where applicable

• Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth), where applicable

• Property and Stock Agents Regulation 2022 (NSW)

Australian Privacy Principles (APP)

Ledger & Lane Property Agents manages personal information in an open and transparent way. This is evident in the implementation of practices, procedures and systems we outline in this policy, that support Ledger & Lane's application of the APPs as its privacy standard, compliance with the APPs where legally applicable, and provide suitable procedures for Ledger & Lane Property Agents personnel to be able to deal with related inquiries and complaints that may be received from time to time.

The following sections of this policy outline how we manage personal information.

Purpose Of Collection (APP1.4c)

Ledger & Lane Property Agents collects your Personal Information for the primary purpose of providing real estate services to our clients and for marketing where you have consented or where otherwise permitted by law. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by clicking the ‘unsubscribe’ link or contacting us in writing.

When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

You do not have to provide us with your personal information, however, if you do not, we may not be able to provide you with our services or information or allow you to inspect property under our control.

We request the information from you so that we can provide you with the services and products you have requested from us, and manage our obligations to you under any customer contract or applicable law. Some of the services we provide as a real estate agency include:

• providing property management, leasing and other real estate services

• Marketing purposes and to provide you with information about products or services that may be of interest to you.

• Enabling us to conduct our business, including meeting any legal or regulatory obligation placed upon us.

We will only collect your sensitive information where it is reasonably necessary for our functions or activities and you have provided us with consent to do so, or where collection is otherwise permitted or required by law. Where possible, we will give you the option of interacting with us anonymously.

The Kinds of Personal Information Collected and Held (APP1.4a)

Ledger & Lane Property Agents collects personal information, which can include:

• Contact information (name, address, phone number, email).

• Occupation

• Emergency contact

• Identification information (such as but not limited to driver's license, proof of age card, passport details, medicare cards)

• Financial information (bank account details, income information)

• Rental and Employment references

• Registered business information

• Property information (details of properties owned, rented, or being sought)

• Financial and credit-related information relevant to assessing applications

• Sensitive information where reasonably necessary, including information provided in connection with domestic and family violence matters

• Other relevant information (family or co-tenant details, employment history, living history, pets)

• Information about staff and directors, as required in the normal course of human resource management and the operation of a business

• Information about current and previous suppliers and clients with whom we have dealings.

How Personal Information is Collected and Held and Used (APP1.4b; APP1.4c; APP1.4f; APP1.4g)

We may collect personal information in a number of ways, including via telephone, email, our website, online forms, tenancy application platforms, social media, face-to-face meetings (including property inspections), and written correspondence.

Where possible, we collect personal information directly from you. However, we may also collect information from third parties where it is necessary to provide our services. These may include:

• tenancy application platforms

• referees or employers provided in rental applications

• landlords, tenants, or owners involved in property management

• other property agents

• contractors or service providers

• strata managers or building managers

• property advertising platforms

• software utilised for real estate purposes

• related entities or referral partners

• anyone authorised to act on your behalf

By contacting us, using our website, submitting an enquiry, applying for a property, or otherwise engaging with our services or agents, you acknowledge that we may collect, use and disclose your personal information as described in this Privacy Policy and as otherwise permitted or required by law.

If you provide us with personal information about another person, you must ensure you have that person’s consent to do so and that they are aware of this Privacy Policy.

We use personal information for the purpose for which it was provided, for related purposes that you would reasonably expect, and as otherwise permitted or required by law.

This may include:

a) Internal Use

• providing property management and real estate services

• providing you with marketing information regarding the services we or third parties acting on our behalf provide

• informing you of properties we have available for lease or other real estate services that may be relevant to you

• responding to enquiries and communications

• communicating with landlords, tenants, clients, contractors and other relevant parties

• reporting to landlords or other clients regarding properties that you may have inspected or made enquiries about

• processing tenancy applications

• arranging repairs, maintenance, inspections, and compliance services

• administration, record keeping and business operations

• Any other purpose associated with our core function as a real estate agency

We may contact you by phone, email, SMS or other communication methods.

b) Disclosure to Third Parties

We may disclose your personal information to third parties to provide our real estate and property management services, subject to the conditions below. These third parties may include related entities, service providers, contractors, professional advisers, business partners, and other parties involved in a property transaction or the management of a property.

We may disclose personal information:

• for the purpose for which it was collected;

• where you have consented to the disclosure;

• for a related purpose that you would reasonably expect, or a directly related purpose where the information is sensitive; or

• where disclosure is otherwise permitted or required by law.

Confidential information obtained while acting for a client or dealing with a customer will only be disclosed with their authority or where permitted or required by law.

c) International Disclosure

In some cases, we use third-party service providers who are located, or who store information, outside Australia. This may include providers of cloud-based software, data storage, IT support, Virtual Assistants, AI-assisted services or customer relationship management systems used in the real estate industry.

As a result, your personal information may be disclosed to, or stored by, recipients outside Australia.

Where this occurs, we will take reasonable steps to ensure that any overseas recipient handles your personal information in a way that is consistent with the Australian Privacy Principles. This includes taking reasonable steps to consider the privacy and security measures applying to the services we use, including relevant contractual or service terms where appropriate.

Due to the nature of cloud-based and third-party services, the countries in which overseas recipients may be located can vary. Where practicable, Ledger & Lane will identify the relevant countries or regions. Further information may also be provided on request.

Automated Decisions

Ledger & Lane Property Agents may use automated or software-assisted systems for the purposes of assisting with tenant application assessment, shortlisting and selection.

Automated decision-making occurs when a computer program or AI is employed to make, or perform an action substantially related to making a decision. Such a decision may significantly affect your rights or interests. In the operation of these computer programs, personal information about you may be used to make decisions or take actions that are directly and substantially related to making those decisions and the services we provide.

As part of this automated decision-making process:

• The kinds of personal information used in the operation of such computer programs include: name, contact details, income, financial and employment information, and other information relevant to assessing a tenancy application.

• The kinds of decisions made solely by the operation of such computer programs or AI may include: NIL.

• The kinds of decisions for which a computer program or AI may assist (but not completely decide), that is substantial and directly related to making the decision, may include processing applications, assessing affordability, providing indicators or ratings, and shortlisting applications.

Ledger & Lane Property Agents ensures that the use of automated or software-assisted systems is fair, transparent, and complies with the Australian Privacy Principles where applicable. You have the right to request information about any automated or software-assisted assessment that affects you and to seek human review of the assessment or decision.

Website Analytics and Cookies

We may use website analytics tools to understand how people use our website, improve our services, and deliver relevant information or advertising. These tools are provided by third-party vendors, such as Google and others.

How information is collected

• Analytics tools may use cookies or other tracking technologies to collect information about your visits, such as pages viewed, time spent on the site, and device information.

• Information collected may include online identifiers like your IP address. When combined with other data, this may constitute personal information.

Vendors we use

• Google

• Meta

Purpose of collection

• To monitor and improve website performance

• To provide relevant advertising or marketing information

• To understand user behaviour and preferences

Opting out

• You can opt out of personalised Google advertising by visiting Google Ads Settings, Meta Ad preferences or through YourAdChoices.

Data Security (APP1.4g; APP11)

Ledger & Lane Property Agents has the following data security measures in place to protect your personal information from unauthorised access, use or disclosure.

Personal information may be stored in a variety of formats, including electronically in databases, in hard copy files and on devices including laptop computers, mobile phones, cameras and other recording devices.

We take reasonable steps (both technical and organisational) to ensure that your personal information is stored both securely and is protected by:

• Maintaining appropriate physical security over our premises, records and systems

• Taking measures to restrict access to only personnel who need that personal information to effectively provide services to you

• Having technical measures in place (e.g. anti-virus software, firewalls, the use of a VPN, secure payment portals, and the use of Secure Sockets Layer (SSL) protocols).

When your personal information is no longer required for the purpose for which it was collected, or a related purpose permitted by this Privacy Policy, we will take reasonable steps to destroy or permanently de-identify it, unless we are required or authorised by law to retain it. We retain personal information for as long as reasonably necessary to comply with our legal, regulatory and operational requirements.

When sending personal information to us, you should take reasonable steps to protect the information and any relevant usernames, passwords or account details. Please notify us as soon as practicable if you become aware of a security breach that may affect information provided to us.

Data Breaches

If Ledger & Lane Property Agents becomes aware of a data breach, an internal response process will commence in accordance with our Data Breach Response Plan. This process includes an assessment of the incident and implementing any necessary containment, notification and rectification measures.

The Licensee in Charge will determine whether the Privacy Act 1988 (Cth), including the Notifiable Data Breaches scheme, applies to Ledger & Lane and, where applicable, any reporting obligations will be managed in accordance with the Data Breach Response Plan.

Accuracy, Access and Correction of Personal Information (APP1.4d)

It is important to us that your Personal Information is up to date. Ledger & Lane Property Agents will take reasonable steps to ensure the information we collect and hold about you is accurate, up-to-date, and complete.

You may access the Personal Information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

If you believe that the information we have is not up to date or inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide a quality service.

Ledger & Lane Property Agents will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information that we hold.

So that we may protect your Personal Information, we may require identification from you before releasing the requested information.

How do I Make Enquiries or Lodge Complaints? (APP1.4e)

If you have an inquiry or complaint relating to our Privacy Policy or our handling of personal information, please contact us using the contact details below. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.

We will refer your inquiry or complaint to our Privacy Officer whose details are below. They will, within a reasonable time, investigate the issue and determine the steps that Ledger & Lane Property Agents will undertake to resolve any complaints. We will contact you if we require any additional information from you and will notify you in writing of the response or determination of our Privacy Officer.

If you are not satisfied with our response or determination, you can contact us again and, where the Privacy Act applies to the matter, you may also raise your concerns with the Office of the Australian Information Commissioner at www.oaic.gov.au.

If you believe we have mishandled your personal information, failed to follow this Privacy Policy or, where applicable, breached the APPs, or you have any questions about this Privacy Policy, please call us immediately on 02 8201 6060.

Revision of Our Privacy Policy

We may revise this Privacy Policy or any part of it from time to time. Please review this policy periodically for changes. The current version of this Privacy Policy will be available on our website at www.ledgerandlane.com.au

The current version of this Privacy Policy applies to our handling of personal information from the date it takes effect. Continued use of our website or services after the policy is updated acknowledges the revised Privacy Policy.

How to Contact Ledger & Lane Property Agents