PRIVACY POLICY

AGENTHUB AU PTY LTD (ABN 89 692 709 390) (“we,” “our” or “us”) operates BuyerHub (buyerhub.au), a buyer-facing property portal used in conjunction with AgentHub (agenthub.au), our real estate management platform for buyer’s agents.

We are committed to safeguarding your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy describes how we collect, hold, use, and disclose your personal information when you use BuyerHub.

BuyerHub and AgentHub are operated as an integrated service by AGENTHUB AU PTY LTD. Information collected through BuyerHub is processed and stored within the AgentHub platform to enable your buyer’s agent to provide property services to you. This data sharing is described in detail in Section 8 below.

We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because:

• It is impractical for the provision of property buying services, which require verified identity for legal compliance
• In some circumstances, it is illegal for our users at AgentHub (buyer’s agents) to deal with individuals who are not identified
• Real estate transactions in Australia require verified identity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), real property conveyancing laws, and agency agreements
• AUSTRAC reporting obligations require us to verify and retain identity information

We may collect and hold a range of personal information about you to provide you with our services, including:

We collect your personal information:

• Directly from you when you complete the onboarding process, update your profile, or communicate with us
• From your buyer’s agent who invited you to BuyerHub — your name, email, phone number, profession, and buyer type may be pre-populated from the invitation
• Automatically via cookies, analytics, and server logs when you use BuyerHub
• From identity verification services (the Document Verification Service) when verifying your identity documents
• From third-party integrations where you have provided consent (e.g., mortgage broker details)

We only collect information that is reasonably necessary for our functions and activities. If you choose not to provide certain information, we may be unable to provide you with some or all of our services, and your buyer’s agent may be unable to assist you with property transactions.

At BuyerHub, we use the Document Verification Service (DVS) to verify a customer’s identity by confirming that the details on their identity document match the government’s records. The DVS is a national online system managed by the Australian Government that allows us to compare information from your identity documents with records held by the document issuer.

The DVS can also confirm that the details on your identity document are still valid and have not expired, been cancelled, or been reported as lost or stolen.

We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for our users at AgentHub to deal with individuals who are not identified.

At or before the time we collect your personal information, we will take reasonable steps to notify you of:

• Our identity and contact details (AGENTHUB AU PTY LTD — see Section 22)
• The facts and circumstances of collection
• Whether collection is required or authorised by law (e.g., identity verification under AML/CTF)
• The purposes for which we collect the information
• The consequences if you choose not to provide the information
• The third parties to whom we may disclose your information, including your buyer’s agent via AgentHub
• This privacy policy and how to access it
• Whether we are likely to disclose information to overseas recipients

We use your personal information for the following primary purposes:

• Providing and maintaining the BuyerHub portal (property shortlists, expense tracking, portfolio management)
• Facilitating the buyer-agent relationship with your assigned buyer’s agent
• Identity verification and compliance with AML/CTF and real estate regulations
• Authenticating and authorising your access (role-based permissions)
• Communicating with you about account activity, property updates, and support

We may also use your information for related secondary purposes:

• Improving platform features, performance, and security
• Anonymised and aggregated analytics
• Protecting against fraud, abuse, or unlawful activity
• Fulfilling legal and regulatory obligations

BuyerHub and AgentHub are operated as an integrated service by AGENTHUB AU PTY LTD. When you are invited by a buyer’s agent and complete onboarding on BuyerHub, your personal information is transmitted to and stored within the AgentHub platform.

• We do not sell or rent your personal information.
• We may share with trusted service providers (hosting, analytics, identity verification) under strict confidentiality agreements.
• We may disclose information where required or authorised by Australian law, including to AUSTRAC, law enforcement, or regulatory bodies.
• We may disclose to prevent serious threats to life, health, or safety of any individual or the public.
• We may disclose for enforcement-related activities conducted by, or on behalf of, an enforcement body.

We will only send you marketing communications if you have opted in during the onboarding process. Marketing consent is separate from the required acceptance of our Terms and Privacy Policy.

• You can opt out of marketing communications at any time by clicking the unsubscribe link in our emails
• We will not use sensitive information (identity documents, financial details) for direct marketing purposes
• Opting out of marketing will not affect your access to BuyerHub services

Your data is hosted on secure cloud infrastructure (Amazon Web Services) which may involve data stored in regions outside Australia, including the United States. We ensure APP 8 compliance via:

• Standard contractual clauses with all overseas service providers
• Adequacy assessments of overseas data protection regimes
• Ensuring overseas recipients are bound by obligations substantially similar to the APPs

Despite overseas hosting, we remain accountable for the handling of your personal information under the Privacy Act.

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, up-to-date, complete, and relevant. You can help us by:

• Updating your profile information through BuyerHub when your details change
• Contacting us if you believe any information we hold about you is inaccurate

Identity verification results are time-stamped and may be periodically re-verified as required by law.

We implement robust technical and organisational measures to protect your personal information, including:

When personal information is no longer needed for any purpose for which it may be used or disclosed under this policy, and we are not required by law to retain it, we will take reasonable steps to securely destroy or de-identify the information.

We collect financial information during onboarding to assist your buyer’s agent in identifying suitable properties. This information is shared with your agent via AgentHub, stored encrypted, and retained for up to 7 years in line with regulatory requirements. You can request deletion subject to legal retention obligations.

BuyerHub does not provide financial advice. Any estimates or projections are for informational purposes only.

We keep your data only as long as needed for the purposes described in this policy, or as required by law:

• Session data: 30 days
• User profiles and buyer records: up to 7 years
• Compliance audit logs: 7 years
• Identity verification records: 7 years
• Financial data: up to 7 years

After the applicable retention period, data is securely deleted or anonymised.

Under the APPs, you have the right to request access to any personal information we hold about you.

• Requests can be made to our Privacy Officer (see Section 20)
• We will respond to all access requests within 30 days
• There is no charge for making an access request; reasonable charges may apply for providing access to large volumes of information
• Access may be refused in specific circumstances permitted by the Privacy Act (e.g., access would reveal evaluative information in commercially sensitive decision-making)
• If we refuse access, we will provide written reasons and inform you of available complaint mechanisms

You have the right to request correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.

• You can update many details directly through your BuyerHub profile
• For other corrections, contact our Privacy Officer (see Section 20)
• We will correct information within 30 days of a request
• If we refuse to correct information, we will provide written notice with reasons and available complaint mechanisms

We use cookies and similar technologies to:

• Manage secure sessions (HttpOnly, Secure, SameSite cookies)
• Remember your preferences
• Analyse anonymised usage via Vercel Analytics (first-party, privacy-focused)

We do not use third-party advertising cookies. You may disable cookies in your browser settings, but this will prevent you from using BuyerHub as session cookies are required for authentication.

We use artificial intelligence to enhance the services we provide to you through BuyerHub and AgentHub. We are committed to being transparent about how AI is used and how your data interacts with AI systems.

We may update this policy from time to time. We will:

• Post the updated policy at this URL with the revised “Last Updated” date and version number
• Notify you by email for material changes
• Your continued use of BuyerHub after notification constitutes acceptance of the updated policy