PRIVACY POLICY

Effective Date: 1 July 2026  Last Reviewed: 1 July 2026 

1. Introduction
   Claire Thompson Homes ABN 84 828 414 208, (referred to as “we”, “us”, or “our”) is a boutique independent real estate business specialising in residential property management and sales. We are committed to protecting your privacy and handling personal information responsibly. This Privacy Policy explains how we collect, hold, use, and disclose personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), to the extent they apply. This Policy particularly addresses our obligations as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) from 1 July 2026. Personal information we handle for AML/CTF compliance (such as identity verification and customer due diligence) is subject to the Privacy Act. Other personal information we handle may also be managed consistently with this Policy where practicable. We may update this Policy from time to time. The current version will be available on our website (if applicable) or at our office. Continued engagement with our services indicates acceptance of the updated Policy.

    

2. What Personal Information Do We Collect?
   We collect personal information that is reasonably necessary for our business functions, including providing property management and sales services, and complying with legal obligations (including AML/CTF). This may include: Contact and identity details: Name, date of birth, residential address, email, phone number, government-issued identification (e.g., driver’s licence, passport). Financial and transaction details: Bank account information, payment details, source of funds/wealth information (for AML purposes), employment/income details. Property-related information: Details about properties you own, manage, or are interested in, tenancy history, references. Other: Communication records, preferences, and any information provided by you or third parties (e.g., solicitors, referees). We may collect sensitive information (e.g., if relevant to identity or background checks) only with your consent or where required/authorised by law. For AML/CTF purposes, we collect information to verify your identity, assess risks, conduct customer due diligence (including beneficial owners), and monitor transactions.

3. How Do We Collect Personal Information?
   We collect information directly from you (e.g., via forms, emails, phone, in-person meetings, tenancy/sales applications, or our website) or from third parties (e.g., referees, credit agencies, public sources, or other parties to a transaction) where lawful. We aim to collect information by fair and lawful means and will notify you of the purposes at or before collection (via this Policy or a specific collection notice). 

4. Why Do We Collect, Use, and Hold Your Personal Information?
   We use your personal information to: Provide property management, sales, leasing, and related services. Communicate with you and manage our relationship. Process payments, invoices, and transactions. Comply with legal and regulatory obligations, including under the AML/CTF Act (e.g., identity verification, record-keeping, reporting suspicious matters or threshold transactions to AUSTRAC). Manage risks, prevent fraud, and maintain business records. Improve our services and for internal administration. If we cannot collect the required information, we may not be able to provide our services to you.

5. Disclosure of Personal Information
   We may disclose your personal information to: Service providers (e.g., IT, accounting, maintenance contractors, solicitors, conveyancers) who assist us and are bound by confidentiality or privacy obligations. Other parties to transactions (e.g., buyers, sellers, landlords, tenants, agents). Regulatory bodies, including AUSTRAC, as required for AML/CTF compliance or other laws. Professional advisers, insurers, or as needed for dispute resolution. Successors if our business is sold or transferred. We do not sell your personal information. Disclosure overseas (e.g., to cloud service providers) will only occur with reasonable steps to ensure equivalent protection.

6. Security and Retention
   We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure (e.g., secure storage, access controls, encryption where appropriate). For AML/CTF records, we retain information for at least 7 years (or as otherwise required by law). Other information is retained only as long as necessary for the purpose it was collected or as required by law, after which it is securely destroyed or de-identified.

7. Access, Correction, and Complaints
   You may request access to or correction of your personal information we hold by contacting us. We will respond within a reasonable time and may require identity verification. There may be a fee for access in some cases. If you have a complaint about how we handled your personal information, please contact us first. We will investigate promptly. If unresolved, you may complain to the Office of the Australian Information Commissioner (OAIC):

• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Website: www.oaic.gov.au

8. Contact Us
   For privacy enquiries, requests, or to obtain a copy of this Policy:
   Claire Thompson Homes, 62 Lobelia Avenue Daisy Hill QLD 4127 +61 434 930 997, claire@clairethompsonhomes.com.au, www.clairethompsonhomes.com.au.
   We encourage you to review this Policy and ask questions before providing information, especially for AML-related collections.