Privacy Policy

Scott Collins @realty Privacy Policy

When used in this privacy policy, the term "personal information" has the meaning given to it in the Privacy Act 1988 (Cth). In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, date of birth, and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

From 1 July 2026, Scott Collins @realty is also a "reporting entity" under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). This means we are required by law to collect, verify, retain and (in certain circumstances) disclose additional personal information about our customers. Section 4 of this policy explains those obligations.

1. What personal information do we collect and hold?

We may collect your name, mailing or street address, email address, telephone number, facsimile number, age or date of birth, profession, occupation or job title and any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise. This includes information you provide to us through our service centre, customer surveys, or visits by our representatives.

AML/CTF identification information — From 1 July 2026, where we are required to conduct customer due diligence (CDD) under the AML/CTF Act, we must also collect:

Full legal name, residential address and date of birth.
Photographic identity documents (e.g. driver licence, passport).
For non-individual customers: company name, ACN/ABN, registered office, beneficial ownership details and details of directors and persons exercising control.
Information about the nature and purpose of the transaction and (for higher-risk matters) the source of funds and/or source of wealth.
A risk rating assigned to you, and any ongoing customer due-diligence (OCDD) information we collect during our business relationship.

Sensitive information — We do not typically collect "sensitive information" (such as health information, racial or ethnic origin, or criminal records) unless it is reasonably necessary for our business functions and you have provided explicit consent, or where required or authorised by law (including under the AML/CTF Act).

2. How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. This occurs through:

Your access and use of our website;
Telephone, letter, fax, or email;
Conversations between you and our representatives;
Contracting with us or entering competitions and promotions;
Completing surveys or providing feedback;
Customer due-diligence and identity-verification requests sent to you in connection with our obligations under the AML/CTF Act, which may be facilitated by a third-party verification provider engaged by us.

We may also collect information from third parties including credit reporting agencies, electronic identity-verification providers (and their data sources), law-enforcement and government entities (including AUSTRAC), your representatives (lawyers/accountants/financial advisors), publicly available sources or any other organisations where you have given your consent.

Anonymity and pseudonymity — Where lawful and practical (for example, general website browsing or initial enquiries), you may deal with us anonymously or using a pseudonym. However, we cannot conduct customer due diligence, enter an agency agreement, or provide a designated service under the AML/CTF Act anonymously — these activities require verified identity information.

3. Cookies and Analytics

In some cases we may also collect your personal information through the use of cookies. When you access our website, we may send a "cookie" (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services.

4. AML/CTF compliance (effective 1 July 2026)

Scott Collins @realty is regulated by AUSTRAC as a reporting entity under the AML/CTF Act. We have implemented an AML/CTF Program and use a third-party customer due-diligence (CDD) and electronic identity-verification provider to capture, verify and securely store the AML/CTF information described in Section 1.

4.1 What we must do

The AML/CTF Act requires us to:

Conduct initial customer due diligence (KYC & KYB) on certain customers — typically sellers and, where applicable, buyers, landlords and other parties — before, or as soon as practicable after, providing a designated service.
Identify and verify the beneficial owners and controllers of non-individual customers.
Assess the money-laundering and terrorism-financing risk of each customer and transaction, and apply enhanced due diligence to higher-risk matters (including obtaining source of funds / source of wealth information).
Conduct ongoing customer due diligence during a business relationship, including monitoring transactions for unusual activity.
Lodge Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs) and other prescribed reports with AUSTRAC.
Maintain records of all of the above for at least 7 years after the end of the business relationship or the date of the transaction (whichever is later).

4.2 Our third-party verification provider

We use a third-party platform to send identity-verification requests, capture identity documents, run electronic identity verification, and securely store the resulting records. When you provide your information through that platform:

Scott Collins @realty remains the data controller for your personal information.
Our provider acts as our data processor under a written contract that requires it to handle your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
Our provider uses encryption in transit and at rest, role-based access controls, multi-factor authentication and other industry-standard security measures.
Some of our provider's sub-processors may be located overseas. Where personal information is transferred overseas, the provider is required to handle it to a standard comparable to the APPs (see Section 9).

You may request the identity of our current AML/CTF verification provider by contacting our Privacy Officer Scott Collins.

4.3 Tipping-off

Where we lodge an SMR with AUSTRAC, the AML/CTF Act prohibits us from disclosing that fact to the customer or any third party ("tipping-off"). For that reason, where you make an access or correction request under Section 10, we may need to decline to confirm or deny the existence of certain AML/CTF records, or to provide only redacted information. We will provide written reasons to the extent permitted by law.

4.4 No marketing use

Personal information collected for AML/CTF purposes is used only for those purposes and to meet our legal obligations. We do not use AML/CTF identification information for direct marketing, research, profiling, or any commercial purpose unrelated to AML/CTF compliance.

5. What happens if we can't collect your personal information?

If you do not provide the information described above, we may not be able to:

Provide the requested products or services to you;
Verify your identity as required under the AML/CTF Act, which may mean we cannot lawfully provide certain designated services;
Provide information about products and services you may want;
Tailor the content of our website to your preferences.

6. Purposes of collection, holding, use and disclosure

We collect, hold, use and disclose your personal information for the following purposes:

to provide products and services to you and to send communications requested by you;
to comply with our obligations under the AML/CTF Act and other laws — including customer due diligence, ongoing due diligence, record-keeping and lawful reporting to AUSTRAC;
to answer enquiries and provide information or advice about existing and new products or services;
to provide you with access to protected areas of our website;
to assess the performance of the website and to improve the operation of the website;
to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties (such as our AML/CTF verification provider);
for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of Scott Collins @realty, its related bodies corporate, contractors, or service providers (other than AML/CTF data, which is not used for marketing);
to provide your updated personal information to our related bodies corporate, contractors or service providers;
to update our records and keep your contact details up to date;
to process and respond to any complaint made by you;
to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator (including AUSTRAC and the OAIC), or in co-operation with any governmental authority of any country.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

7. To whom may we disclose your information?

We may disclose your personal information to:

Our employees, related bodies corporate, contractors, and agents;
Service providers (web hosting, IT, mailing houses, payment processors, debt collectors and professional advisors);
Our AML/CTF verification provider and other identity-verification or data-source providers, for the purposes set out in Section 4;
AUSTRAC and other law-enforcement, regulatory or government bodies, where we are required or authorised by law to do so (including via SMRs, TTRs and other prescribed reports);
Suppliers and third parties with whom we have commercial relationships for marketing purposes (other than AML/CTF data);
Any organisation where you have provided express consent.

8. Direct Marketing

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).

You may opt-out at any time by contacting our Privacy Officer Scott Collins or using the opt-out facilities provided in the communication; we will then ensure that your name is removed from our mailing list.

As noted in Section 4.4, AML/CTF data is never used for marketing.

9. Overseas disclosure

We may disclose personal information to recipients located outside Australia for data hosting, IT support, customer due-diligence verification and other services. Where personal information is transferred overseas, we (and our processors) either enter into written agreements requiring the recipient to handle the information to a standard comparable to the Australian Privacy Principles, or rely on another permitted safeguard under APP 8.

10. How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There are limited circumstances in which we may need to refuse or restrict access — for example, where granting access would interfere with the privacy of others, breach confidentiality, be unlawful, prejudice an investigation, or result in a breach of the AML/CTF Act, including the tipping-off prohibition (see Section 4.3). If we refuse or restrict access we will give you written reasons to the extent permitted by law.

11. Storage, Security and Retention

We hold your personal information in both hard copy and electronic forms. We take all reasonable steps to protect your information from misuse, interference, loss, or unauthorised access through technical security measures (such as firewalls and encryption) and restricted physical access.

Retention — We retain personal information only for as long as is reasonably necessary for the purposes for which it was collected, or for any longer period required by law. In particular, AML/CTF records (including identity verification data and transaction records) must be retained for at least 7 years after the end of our business relationship with you, or after the date of the relevant transaction (whichever is later). Once personal information is no longer needed and is not required to be retained, we will take reasonable steps to securely destroy or permanently de-identify it.

Data breach notification — In the unlikely event of an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

12. Complaints and Disputes

If you believe your privacy has been breached, please contact our Privacy Officer Scott Collins. We will investigate the incident and contact you within a reasonable time to discuss a resolution.

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Web: www.oaic.gov.au
Phone: 1300 363 992

Complaints about AML/CTF reporting are not within the OAIC's jurisdiction; AUSTRAC handles compliance complaints in relation to the AML/CTF Act.

13. Links

Our website may contain links to other websites operated by third parties (including our AML/CTF verification provider's customer portal). We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.

14. Contacting us

If you have questions about this policy or wish to lodge a complaint, please contact:

Scott Collins

Scott Collins @realty

B8 / 19-23 Macauley Place, Bayswater VIC 3153

Phone: 0499 005 265

Email: scottcollins@atrealty.com.au

Web: www.scottcollins.com

This privacy policy may be updated from time to time.

Last updated: 01/09/2026