Privacy Policy

Introduction

Listing Loop Australia Pty Ltd ACN 628 994 276 and its related bodies corporate (Listing Loop, we, our) are committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business.

Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.

Please take a moment to read this Privacy Policy as it explains how we manage personal information including our obligations and your rights in respect of our dealings with your personal information.

Key definitions

In this document:

• “Agent Assist” means a Licenced Principal, Real Estate Agent, or Property Developer who is available to provide advice where legally permitted to and assistance to a Buyer upon request.
• “APPs”means the Australia Privacy Principles set out in the Privacy Act;
• “Buyer” means a registered user who is interested in viewing or purchasing a property.
• “personal information”has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
• “Privacy Act”means the Privacy Act 1988 (Cth);
• “Selling Agent” means the agent who is responsible for selling the advertised property on the platform whether it be a Licenced Principal, Real Estate Agent or Property Developer.
• “Sensitive information”has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation, religious beliefs or affiliations and criminal record.

One of the primary ways that we collect and handle personal information is through the Listing Loop platform, which is available at our website located at www.listingloop.com.au (the Website).

Please refer to the Terms of Use for the Website (available at www.listingloop.com.au/terms-conditions/) (Terms of Use). The Terms of Use set out the requirements for using the Listing Loop platform, and provide further details about how the platform works and the types of information that may be collected and processed when you use the platform.

1. The right to be forgotten & data deletion

If you are a user of the Listing Loop platform and have provided your information to us after registering as a user, you have the right to request your data be deleted the platform. In order to do this, please head to this link.

Once you have submitted your data deletion request, we will respond to you within 3 business days, giving you confirmation that your data has been deleted.

2. How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:

a. when you register with and use the Listing Loop platform, or otherwise use the Website;

b. in administering and performing any contracts with service providers;

c. when you contact us via telephone or other means;

d. from correspondence (whether in writing or electronically);

e. while conducting customer satisfaction and market research surveys;

f. when administering any of our services; and

g. as otherwise required to manage our business.

However, in certain cases we may collect personal information from publicly available sources and third parties, such as suppliers, recruitment agencies, your employers, contractors, our clients, business partners.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

3. Types of personal information we collect

The type of personal information we may collect can include (but is not limited to) your name, postal address, current address, email address, phone numbers, date of birth.

Depending on the nature of our relationship with you, we may also collect information including credit card details, bank details, drivers licence, billing information, current and former employment details.

If you register an account on the Listing Loop platform, the types of personal information that we collect about you will depend on what type of account you register. For example:

a. If you are a Buyer, we will collect information that you provide us about your property preferences and criteria, as well as information about how you use the Website and interact with the properties that are listed.

b. If you are an Agent or Agency Principal (as defined in the Terms of Use), we may collect information about your job title and agency, your real estate licence, as well as professional contact details and other related information.

We will also collect any information that you provide us to complete your user profile for the Listing Loop platform, including any photo you choose to provide. This information will be displayed as part of your user profile on the platform, and shared with other users as you use the platform. For example, a Buyer’s photo will be visible to their Agent Assist and will also be shared with the relevant Selling Agent when a Buyer submits a property enquiry in relation to a listed property.

When you sign in to the Listing Loop platform, we log certain data about the activities you conduct through your user account (such as properties you view and connections you make with other users).

We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services.

4. Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances.

We collect, hold, use and disclose personal information to:

a. confirm your identity;

b. operate the Listing Loop platform, which allows users to connect with each other and (among other things) share information via direct messaging and post information to open forums on the platform;

c. offer and provide you with our goods and services;

d. send you Listing Loop newsletters, offers for our products and services (and products and services of our trusted partners) and notifications to which you have subscribed;

e. manage and administer those goods and services, including account keeping procedures;

f. optimise and customise the user experience (including content and advertising) for users of the Listing Loop platform and our other websites and services;

g. protect the security and integrity of the Listing Loop platform and our other website and services;

h. develop and improve the Listing Loop platform and our other products and services;

i. to produce and commercialise datasets and data reports, as described in the Terms of Use;

j. communicate with you, including (but not limited to) emailing you tax invoices;

k. comply with our legal and regulatory obligations; and

l. otherwise to manage and develop our business, including rewarding a Listing Loop platform participants (such as a real estate agent that acts on your behalf) who has introduced you to us or our related bodies corporate

5. Who we disclose your personal information to

The types of persons, agencies and entities we typically disclose personal information to include (but are not limited to) our suppliers, contractors (such as any mail house), trusted partners who offer products and services that we think you may be interested in (such as financial advisors, insurance providers, property services and utility providers), organisations that provide us with technical and support services (these include third party technology service providers to assist us with storing and processing user data as part of the website’s operations) and our professional advisors.

We may share your information with your representative or any person acting on your behalf (for example, a real estate agent).

Further, Listing Loop often works cooperatively with its related bodies corporate within the Listing Loop Global group, and may disclose your personal information to these entities. We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.

If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

When you use the Listing Loop platform via the Website, some of the features may involve sharing your personal information with other users (including the property matching function, direct messaging and public forums). You can use your account’s privacy settings on the Website to manage who has access to your information. Please carefully consider what information you choose to share with other users and post on the Listing Loop platform.

As part of the Listing Loop platform’s focus on matching prospective buyers and agents of properties, we track certain user activities on the platform and may provide Agents and Agency Principals with certain statistics, insights and reporting. For example:

1. if you are a Buyer, information that you upload to your Buyer dashboard will be visible to your Agent Assist and the Selling Agent within their Agent Dashboard interface;
2. when a Buyer “unlocks” a property listing on the Platform to view the full details of the property:
   1. the Selling Agent will be sent a notification that the Buyer has “unlocked” the property listing; and
   2. the Agent Assist for that Buyer will also be sent a notification that Buyer has “unlocked” a property listing in the relevant suburb; and
3. sales data for transactions brokered through the platform may be shared with the Buyer’s Agent Assist and the seller’s Selling Agent.

6. Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases and ensuring that employees and third parties with access
to records containing personal information are subject to appropriate information security obligations.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

7. Direct marketing

Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities. We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you.

You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request by contacting our Privacy Officer.

8. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website. This information will help to better adapt the Website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Website. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website.

Without limiting the above, we may also use the cookies on the website (as well as data collected through these cookies) for other commercial purposes, including targeting and displaying advertising on the Website and on third party websites, social media platforms and advertising networks.

9. Accessing and correcting your personal information

You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

10. Overseas transfers of personal information

We may disclose your personal information to our related entities, service providers and agents located overseas, including in Sweden, the United Kingdom, India and the United States of America. From time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

11. Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer:

The Privacy Officer
1 Fuji Crescent, Mornington, Victoria, 3931, Australia, or GPO Box 1393, Melbourne, Victoria, 3001, Australia.
Telephone 1300 695 667
Email [email protected]

We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]

12. Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you.