Privacy Policy

Crossmatch is operated by Project Gemini 55 Pty Ltd (referred to in this Privacy Policy as "Crossmatch", "we", "us" or "our").

Crossmatch respects the privacy of the people we deal with and is committed to protecting personal information.

This Privacy Policy explains how Crossmatch collects, holds, uses, discloses and otherwise manages personal information in connection with our business, website and services.

Crossmatch provides property information, sourcing and notification services designed to identify and communicate off-market, pre-market, pipeline, newly listed and other property opportunities primarily within buyers' nominated geographical areas. Our service is not an individually tailored property search service and does not involve acting as a buyer's agent or representing buyers in property transactions.

We manage personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles where they apply to us, together with other applicable Australian privacy, marketing, real estate and regulatory requirements.

This Privacy Policy applies to personal information collected through our website at crossmatch.au, online forms, buyer onboarding processes, referrals, email, telephone, SMS, WhatsApp, social media, payment processes and our dealings with buyers, referring agents, listing agents, service providers and other third parties.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not that information is true or recorded in a material form.

Personal information may include information such as your name, address, telephone number, email address, occupation and other information that identifies you or can reasonably be linked to you.

Certain categories of information are treated as sensitive information under the Privacy Act and receive additional protection.

Crossmatch does not generally seek to collect sensitive information unless it is reasonably necessary for our activities, you consent where required, or its collection is otherwise permitted or required by law.

The personal information we collect depends on your relationship with Crossmatch and the services you request.

For buyers, prospective buyers and other individuals, we may collect:

• –your name, telephone number, email address and other contact details
• –your residential address where reasonably required
• –your preferred geographical areas, purchasing budget and property type
• –information provided to us by a referring real estate agent or another authorised third party
• –records of communications and interactions with Crossmatch
• –onboarding, contractual and consent information
• –limited payment and transaction information
• –information reasonably required to verify your identity or comply with legal or regulatory obligations, where applicable
• –information relating to enquiries, complaints or requests made to us
• –any other information you voluntarily provide that is reasonably relevant to the services we provide

Crossmatch collects personal information only where reasonably necessary for its business activities or otherwise permitted or required by law. Buyers are not required to provide detailed financial or individual purchasing information unless it is reasonably necessary for a particular service function or legal obligation.

Where reasonably practicable, Crossmatch collects personal information directly from you.

This may occur when you:

• –make an enquiry about Crossmatch or our services
• –complete an online form or register through our website
• –onboard as a buyer
• –communicate with us by telephone, email, SMS, WhatsApp, social media or another electronic method
• –provide information about your property requirements
• –enter into an agreement with us
• –make a payment
• –participate in a survey, promotion or feedback process
• –otherwise communicate or deal with Crossmatch

A core part of Crossmatch's business involves referrals and introductions within the real estate industry.

A real estate agent or other third party may provide Crossmatch with a buyer's contact details and relevant property requirements where the buyer has authorised or consented to that information being disclosed and to Crossmatch contacting them.

Where a person or organisation provides Crossmatch with personal information about another individual, we expect them to have the authority to provide that information and, where required, to have obtained appropriate Consent to Disclose & Contact.

Where we receive your personal information from another person or organisation, Crossmatch will take reasonable steps, where required, to make you aware that we have collected your information, the circumstances of the collection and the purposes for which we intend to use it.

You are not required to provide personal information to Crossmatch unless required by law.

However, if information reasonably required for our services is not provided, we may not be able to:

• –establish or maintain your buyer profile and geographical notification preferences
• –identify the geographical areas in which you wish to receive property opportunities
• –provide property notifications or communicate information about available opportunities
• –complete your onboarding
• –verify your identity where legally required
• –communicate with you effectively
• –comply with applicable legal or regulatory requirements
• –provide some or all of our services

Crossmatch may collect, hold, use and disclose personal information where reasonably necessary for our business activities, including to:

• –provide and administer our property information, sourcing and notification services
• –understand a buyer's nominated geographical areas and general property preferences
• –identify potential off-market, pre-market, pipeline, newly listed or other property opportunities
• –organise and distribute property opportunity notifications, primarily according to nominated geographical areas rather than individual property matching
• –facilitate communication with participating listing or selling agents where relevant and appropriately authorised
• –communicate with referring agents in relation to referrals and, where appropriate, referral outcomes
• –manage onboarding, agreements, fees and payments
• –communicate with buyers, agents and other parties
• –respond to enquiries, requests and complaints
• –maintain and update our records
• –improve our services, processes, systems and website
• –conduct internal administration, analysis, planning, research and business development
• –protect Crossmatch, our clients and others from fraud, misuse or unlawful activity
• –obtain professional advice and manage legal, accounting, insurance or compliance matters
• –meet contractual, regulatory and legal obligations
• –comply with applicable real estate, privacy, AML/CTF and other laws
• –communicate information about Crossmatch services and opportunities where permitted
• –undertake other purposes disclosed to you at the time your information is collected or otherwise permitted by law

Australian laws may require businesses providing certain property-related services to undertake identity verification, customer due diligence, record keeping or other regulatory activities.

Where Crossmatch is required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), associated Rules or other regulatory requirements, we may collect and use personal information reasonably required to:

• –establish or verify your identity
• –conduct customer due diligence
• –assess regulatory or financial crime risk
• –maintain records required by law
• –satisfy reporting obligations
• –otherwise comply with applicable regulatory requirements

Where reasonably necessary for the purposes described in this Privacy Policy, Crossmatch may disclose personal information to:

• –listing, selling or other real estate agents in connection with property opportunities
• –referring agents where relevant to the referral arrangement and permitted by law
• –property owners or their authorised representatives where necessary and appropriately authorised
• –buyer's agents, solicitors, conveyancers, mortgage brokers or other property professionals where you request, authorise or reasonably expect the disclosure
• –accountants, lawyers, consultants, insurers and other professional advisers
• –payment processors and financial service providers involved in processing payments
• –cloud hosting, CRM, communications, website, software, data-storage, cybersecurity and other technology service providers
• –identity verification and compliance service providers where applicable
• –marketing, analytics or communications providers where permitted
• –regulatory bodies, government authorities, AUSTRAC, courts, tribunals and law enforcement agencies where required or authorised by law
• –a prospective purchaser, investor, business partner or adviser in connection with a proposed or actual investment, sale, merger, restructure or transfer of all or part of our business, subject to appropriate confidentiality and legal requirements

Where a buyer has provided appropriate authorisation during registration or onboarding, Crossmatch may share relevant buyer information, including their name, contact details, preferred geographical areas and general property interests, with multiple participating selling agents and agency principals for the purposes explained in that authorisation.

Separate approval will not ordinarily be sought for each individual disclosure that falls within the scope of an existing valid authorisation.

Buyers may contact Crossmatch to withdraw or modify an authorisation, subject to applicable law. Withdrawal may affect Crossmatch's ability to provide service functions that require the relevant disclosure.

Any subsequent marketing or other use of buyer information by participating agents remains subject to applicable privacy and electronic marketing laws.

Crossmatch may send information about our services, property opportunities, new or relevant services, business updates, educational material or other information we reasonably believe may be relevant to you, where we have consent or are otherwise permitted by law.

These communications may be made by email, SMS, telephone, WhatsApp, social media messaging services or other permitted communication channels.

Communications may include property opportunity notifications associated with the service for which a buyer has registered, as well as promotional or marketing communications where permitted by law.

Where a communication constitutes a commercial electronic message, Crossmatch will comply with applicable requirements, including the Spam Act 2003 (Cth).

Marketing communications will identify the sender and provide an appropriate means of unsubscribing.

You may opt out of receiving direct marketing at any time by using the unsubscribe facility provided in the communication or by contacting Crossmatch directly. We will take reasonable steps to action your request.

Opting out of marketing does not prevent Crossmatch from sending necessary service, transactional, contractual, regulatory or administrative communications.

Crossmatch does not use sensitive information for direct marketing unless permitted by law.

When you use crossmatch.au, Crossmatch and our technology providers may collect information about how the website is accessed and used.

We may use cookies, pixels, analytics tools and similar technologies to operate and secure the website, remember preferences, understand website traffic and usage, measure the effectiveness of content or campaigns, improve our website and services, and support advertising or marketing activities where permitted.

Some cookies may be necessary for operation of the website, while others may relate to analytics or marketing.

You can generally control or disable cookies through your browser settings, although disabling certain cookies may affect website functionality.

Third-party analytics, social media, advertising, payment or technology providers may collect information through their own technologies and handle that information in accordance with their own privacy policies.

Our website, emails or other communications may contain links to third-party websites, applications or services.

Crossmatch does not control the privacy or information-handling practices of independent third parties, and this Privacy Policy does not govern information collected directly by those parties.

You should review the privacy policies and terms of relevant third parties before providing personal information directly to them.

The inclusion of a third-party link does not necessarily constitute an endorsement by Crossmatch of that website or service.

Where practicable and lawful, you may interact with Crossmatch without identifying yourself or by using a pseudonym.

For example, you may generally browse publicly available areas of our website without identifying yourself.

However, it may be impracticable for Crossmatch to establish and administer buyer profiles, provide property opportunity notifications or deliver other registration and communication services without knowing your identity and obtaining relevant contact information and geographical preferences.

We may also be required by law to establish or verify a person's identity in particular circumstances.

Crossmatch uses technology, software, payment, communications and cloud service providers in operating our business.

Some providers or their subcontractors may store, process or access personal information outside Australia.

Where personal information is disclosed to an overseas recipient, Crossmatch will take reasonable steps as required by applicable privacy law in relation to the handling of that information.

Where required and practicable, Crossmatch will identify relevant overseas locations in this Privacy Policy, an applicable collection notice or other privacy disclosure.

Crossmatch takes reasonable steps to protect personal information against misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure.

Depending on the nature of the information, these measures may include password protection, access controls, authentication processes, secure cloud and technology systems, controlled user permissions, data security and cybersecurity practices, appropriate staff and contractor controls, and other reasonable technical and organisational safeguards.

While Crossmatch takes reasonable steps to protect personal information, no method of electronic transmission or storage can be guaranteed to be completely secure.

You should also take reasonable precautions when communicating personal or confidential information electronically.

Crossmatch retains personal information only for as long as reasonably required for the purposes for which it was collected, or as necessary to satisfy legal, regulatory, contractual, accounting, taxation, dispute-resolution, fraud-prevention, insurance, governance or other legitimate business requirements permitted by law.

Buyer profile information may be retained while a profile remains active and may be reviewed, updated or deactivated in accordance with Crossmatch's buyer profile management procedures and Terms and Conditions.

Crossmatch may retain records of onboarding, payment transactions, acceptance of Terms and Conditions, privacy authorisations and relevant communications where reasonably necessary for administration, compliance or dispute resolution.

Where personal information is no longer required for a permitted purpose and Crossmatch is not required by law to retain it, we will take reasonable steps to destroy it or permanently de-identify it.

Crossmatch maintains processes for responding to suspected loss, unauthorised access, unauthorised disclosure or other breaches involving personal information.

If Crossmatch becomes aware of a suspected data breach, we will assess the incident and take reasonable steps to contain and address it.

Where the Notifiable Data Breaches scheme applies and Crossmatch is required to make a notification, we will take the steps required by law, which may include notifying affected individuals and the Office of the Australian Information Commissioner.

You may request access to personal information Crossmatch holds about you. Requests should be made using the contact details set out below.

Before providing access, Crossmatch may need to verify your identity. We will respond to access requests within a reasonable period.

Crossmatch will not charge you merely for making an access request. In circumstances permitted by law, we may charge reasonable costs associated with providing access to information.

There may be circumstances in which Crossmatch is permitted or required to refuse access to some or all of the information requested. Where required by law, we will provide written reasons for a refusal and information about available complaint mechanisms.

Crossmatch takes reasonable steps to ensure that personal information we hold is accurate, up to date, complete, relevant and not misleading for the purposes for which it is used.

If you believe information Crossmatch holds about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to correct it.

We may need to verify your identity before making a correction. Where required by law, we will notify relevant third parties of corrections where appropriate and reasonably practicable.

If you believe Crossmatch has not handled your personal information appropriately or has breached an applicable privacy obligation, please contact our Privacy Officer using the details below.

Please provide sufficient information for us to understand and investigate your concern. Crossmatch will acknowledge and investigate privacy complaints and will aim to respond within a reasonable period.

If you are dissatisfied with our response and the Privacy Act applies to your complaint, you may be entitled to refer the matter to the Office of the Australian Information Commissioner (OAIC). Further information about privacy rights and complaints is available at oaic.gov.au.

Crossmatch may use technology and software to assist with administration, data organisation, property sourcing, geographical filtering, property opportunity broadcasting and notifications, buyer and property information management, workflow management and other business processes.

Technology may assist Crossmatch in identifying or organising potential property opportunities and distributing notifications to buyers based primarily on their nominated geographical areas. However, Crossmatch does not currently arrange for personal information to be used by a computer program to make solely automated decisions that could reasonably be expected to significantly affect an individual's rights or interests in a manner requiring specific disclosure under applicable privacy law.

If our technology or decision-making practices change, we will update this Privacy Policy where required.

Crossmatch may amend this Privacy Policy from time to time to reflect changes to our business, services, technology and systems, information-handling practices, service providers or legal and regulatory obligations.

The current version of this Privacy Policy will be published on our website and will take effect from the date shown at the beginning of the policy. We encourage you to review this Privacy Policy periodically.

For questions about this Privacy Policy, privacy enquiries, requests to access or correct personal information, requests to opt out of marketing or privacy complaints, please contact:

Privacy Officer Crossmatch Project Gemini 55 Pty Ltd Email: [email protected] Website: crossmatch.au