Your privacy is important to us, Melbournia and each of its associated entities (as that term is defined in the Corporations Act 2001 (Cth) from time to time) (Melbournia). This policy discloses how we collect, protect, use and share information gathered about you.

Melbournia takes all reasonable steps to comply with Australia Privacy Principles and Act 1988 (Cth) (Privacy Act) with respect to the collection, use, disclosure, security of, and access to personal information.

How We Collect Information

Generally, we collect personal information when you write to or email us, when you access and use our website and when you participate in surveys, questionnaires and/or promotions run by or on behalf of us, during conversations between you and our representatives, or generally through your communication with us.

We may collect and hold personal information that can identify you in order to conduct our business or communicate with you. The personal information collected by Melbournia depends on your interaction with Melbournia.

Melbournia may collect and hold information about individuals who use our services or otherwise interact with us as part of a transaction or communicate with us.

Melbournia may collect information about you from the following third party sources:

• various databases in the public domain, Australia Post DPID database, Titles Office or other property databases;
• credit reporting bodies, law enforcement agencies and other government entities; and
• referrals and recommendations from existing clients of Melbournia.

As part of its due diligence process prior to entering into lease or rental agreements with you, Melbournia may disclose your information to authorised credit-checking agencies.

What Information We Collect

The kinds of personal information that we collect may vary depending on our interaction with you. It may include your:

• name, address and other contact details (like your telephone number);
• email address;
• date of birth; and
• gender;
• any preferences that you select; and
• any other personal information which may be required in order to facilitate your dealings with

  us.

Without this information we would not be able to conduct our business which involves the provision of products and services to you.

If you are a current or prospective vendor, purchaser or landlord of real estate or if you visit our website or make an enquiry with us via another method:

• contact details (including, name, address, telephone number and email address);
• driver's license number;
• current property ownership and title details;
• desired property ownership details; and
• details of properties sold or acquired by you.

If you are a current or prospective tenant for a rental property, Melbournia may also collect the following information from you:

• contact details (including, name, address, telephone number and email address);
• drive's license number;
• employment details such as your employment status, employer, salary, length of employment;
• other sources of income; and
• personal and financial referees who we may contact about your application.

If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses and other financial details. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.

Sometimes Melbournia may also need to ask you for other forms of Personal information to enable us to provide services to you.

How We Hold Your Personal information

When we receive information in hard copy form, we enter the information on our system and then destroy the hard copy after this is done.

Information that is received electronically or entered on our system from hard copy documents is stored on two servers that are located in the Australia and cloud CRM system. The servers and CRM are secure and access is password protected. Level of access is restricted to employees of Melbournia.

Why We Collect, Hold, Use and Disclose Your Personal Information

Melbournia collects this information for a range of purposes including:

• to enable Melbournia to provide you with the services and/or products you may require;
• to comply with local, state and federal legislation or regulations, including with respect and in relation to real estate property sales, rental and administration;
• to enable Melbournia and its third party partner businesses to assist you with related or ancillary services, as required;
• for our internal administrative, marketing, planning, product development and research requirements
• to share your personal information within the Melbournia Group (including between Melbournia's related entities and Melbournia franchisees), contractors or service providers, as deemed necessary;
• to maintain Melbournia's records and keep your contact details up to date;
• to deal with your enquiries or customer service issues promptly, whether by email, telephone or mail;
• to keep you up-to-date with services we think would be of interest to you;
• to conduct relevant business processing functions; and
• to process and respond to any complaint made by you.

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

How We Use Your Personal Information

Melbournia may use personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. Our potential uses of personal information which Melbournia collects (and for which you consent to its use may include:

• compliance with obligations under real-estate regulations and laws applicable to Victoria;
• helping Melbournia efficiently and effectively deliver and improve on products and services;
• for any other purpose where you would reasonably expect Melbournia to use or disclose that personal information especially where it is relevant to the primary purpose for which the information was initially collected;
• to provide you with access to protected areas of our website, to assess the performance of our website and to improve the operation of our website;
• to conduct business processing functions including sharing personal information within Melbournia, with its contractors, service providers or other third parties; and
• for Melbournia's administrative, planning, product or service development, quality control and research purposes; and
• complying with any other relevant laws or regulations.
• to assist in identifying ways in which we can provide you with a better service, or enhance your experience of our website and mobile site or other services;
• for our financial and operational processes;
• so that we can promote our products and services to you and the products and services of third parties with whom we deal;
• to allow our related companies to promote their products and services to you and those of their partners;
• detecting and preventing fraud;
• for business research and development of new products and services;
• to facilitate the competitions, special offers and promotions that we or our partners run;
• to display content and advertising that are customised to your interests, preferences and experiences;
• to verify your identity;
• so that we can respond to inquiries and complaint handling; and
• to comply with our legal and regulatory obligations and enforce our legal rights and/or defend claims made against us.

In addition, we are permitted to use or disclose personal information held about you:

1. a) where you have consented to the use or disclosure;
2. b) where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety;
3. c) where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
4. d) where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
5. e) where we reasonably believe that the use or disclosure is necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body.

Direct Marketing and Research

As set out above, Melbournia may use personal information about you for marketing and research purposes. However, you can manage your Melbournia communication preferences by contacting us. In addition, the marketing communications that we send you may also contain information on how to unsubscribe from those communications.

You can tell us at any time if you do not want us to disclose your details to other organisations such as our related companies or third parties for marketing purposes. To do this, you just need to contact us (our contact details are set out below in this policy). Sometimes we may extract information from our collected records to produce aggregated sales data. This aggregated data does not identify individuals. Melbournia uses the aggregated sales data for research purposes and may share the data with third parties.

Disclosing and Sharing of Data

We do not sell personal information.

We may share the personal information you provide with companies affiliated with Melbournia. We may share this information with our related companies and with Melbournia business partners.

We may disclose your personal information to third parties for the primary purpose for which the information was collected or for related purposes, to provide you with a service or information that you requested or consented to receive from us.

We may also disclose your personal information to various law enforcement agencies and government authorities.

We may use your personal information to establish, exercise or defend a legal or equitable claim. We may use your personal information for the purposes of confidential alternative dispute resolution. Your information may also be shared between related entities within our business group where necessary to fulfil our purposes.

We may engage third party contractors to perform services for us which involve the contractor handling personal information we hold. For example, we may engage third party contractors to:

• provide after-sale services
• provide delivery services
• provide email and mail handling services
• provide electronic funds transfer services, credit card account processing and related services
• operate call centers
• conduct market research
• provide information technology services such as data storage, website hosting, communication networks, software and system development and maintenance.

In these situations, we take steps to prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it to that third party contractor.

Other than the above and as otherwise expressly stated elsewhere in this Privacy Policy, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.

Cookies, Tracking and Advertising

For each visitor to our website, our server automatically recognises and stores the visitor's IP address. In addition, our website uses cookies. To enhance your experience when using our website, these cookies may automatically collect information from you such as your postcode, preferences, region and sign in username (if applicable). Our website may also carry third party cookies, which automatically collect anonymous information from you, such as your demographics and interests. This information may be disclosed to third parties for the purpose of providing you, and others, with a more targeted advertising experience both on and off the Melbournia website. Most web browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies. Note that rejecting cookies will disable certain features in the use of our website. We also use cookies for tracking the statistics of our website. This allows us to better understand our users and improve the layout and functionality of our website. This tracking is conducted in such a way to ensure the anonymity of visitors.

Sometimes our website contains links to third party websites, for your convenience and information. When you access a non-Melbournia website, please understand that Melbournia is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.

Remarketing

Melbournia actively uses and reserves the right to use advertising mediums with remarketing capabilities. Vendors such as Google Ad words display adverts created by us on search engines, web pages and applications throughout the internet. Such vendors may track your online behaviour (cookies) and serve ads based on your past visits or perceived topics of interest.

Should you wish to opt out of Google's use of cookies, you can do so by visiting the google ad settings page https://adssettings.google.com

Google Analytics

We use Google Analytics to track trends and behaviour on our websites. For example, to identify which pages are most popular, so we can ensure that we provide more relevant content that you as a visitor wish to view. We use this analysis to improve content and functionality of our website and a better user experience. Google Analytics advertising features including remarketing, demographic and interest reporting are also used by Melbournia. These features help to target our advertising efforts, so our messages are being sent to those who are most likely to engage with them and find them useful.

Should you wish to opt out of Google Analytics advertising features, you can do so via your ad settings or the use of Google Analytics opt-out browser add on. https://tools.google.com/dlpage/gaoptout/

Access to and Correction of Information about You

Where we are required by law, we will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information. We may recover from you our reasonable costs of supplying you with access to the information we hold about you but will not charge you for lodging the request itself. Access to personal information will be given to you in the manner requested if it is reasonable to do so. Your request to provide access to this information will be dealt with in a reasonable time.

If we refuse to provide you with access to the information we hold about you, we will provide you with written reasons for the refusal and inform you of any exceptions relied upon under the Australia Privacy Principles.

Anonymity and Pseudonymity

You have the option of dealing with Melbournia anonymously however this only applies where it is practicable for us to do so, such as providing response to a general enquiry.

For most other functions and activities, we will need your name and contact information and enough information about the particular matter to enable us to adequately serve you and perform our regular business function. In these circumstances it would not be practical for you to operate under a pseudonym.

Keeping Your Personal Information Up-to-Date

We take reasonable steps to ensure that the personal information we hold about you is relevant, accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

Storage and Security of Your Personal Information

We take reasonable steps to protect the security of your personal information in accordance with this Privacy Policy. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

While we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us or obtain from our online services (if relevant). Accordingly, use is at your own risk.

Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification, interference or disclosure. Once personal information is no longer needed, it will be permanently de-identified or destroyed.

However, we do not promise that your personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur. If we provide you with any passwords or other security devices, it is important that you keep these secret and confidential and do not allow them to be used by any other person.

Resolving Your Concerns

If you wish to gain access to your personal information, have a complaint about a breach of your privacy or you have any query about how your personal information is collected or used please forward your request, complaint or query to the address below. We will respond to your query or complaint as soon as possible.

Changes to this Privacy Policy

We may amend this Privacy Policy as our business requirements demand or the law changes. Any changes to this Privacy Policy will be updated on www.melbourniagroup.com.au, so please visit www.melbourniagroup.com.au periodically to ensure that you have our most current Privacy Policy.

Opting out of Marketing Communications

You may be contacted by mail, telephone or email for purposes of customer service or to be notified about related products, promotions, newsletters, customer surveys and/or similar materials that we may conduct or distribute from time to time.

If you do not wish to receive any such communications, you may advise us that you wish to opt out:

• E-mail us at: unsubscribe@melbourniagroup.com.au
• Call us at: (+61 3) 9078 2188
• Write to us at: 125 Grey Street, St Kilda 3182, Victoria, Australia

Or if your customer does not wish to receive any such communications, you have an obligation to remove them within 5 days.

Changes to our Privacy Policy

Without further notice to you, Melbournia may decide to or may be required to change this Privacy Policy. Any changes will be posted on this Privacy Policy page so that users can be made aware of and have access to the information that Melbournia collects, how it is used and the way in which information may be disclosed. As a result, please remember to refer back to this Privacy Policy regularly to review any amendments.

How to Contact Us?

If you would like to update your contact information or preferences, access your personal information, make a complaint or have your information removed from our mailing lists, you may contact:

• The Privacy Officer, 125 Grey Street, St Kilda 3182, Victoria, Australia
• Email: unsubscribe@melbourniagroup.com.au
• Telephone: (+61 3) 9078 2188

The above policies are effective as of 12 December 2018. Melbournia and each of its associated entities reserves the right to change this policy at any time. The use of information that we gather now is subject to the Privacy Policy in effect at this time. Users wishing to see the changes should do so by visiting our web site privacy policy statement.