Privacy Policy

Fraser & Co
Privacy Policy

Fraser & Co Pty Ltd (ABN 60 010 854 562) ("Fraser & Co", "we", "our", "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, hold, use and disclose your personal information, and how you can access or correct it. It applies to all personal information we collect through our website (fnco.au), our customer relationship management systems, our communications with you, and during the course of our real estate services. It is governed by the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and from 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) as it applies to real estate professionals under Tranche 2.

WHAT IS YOUR PERSONAL INFORMATION?
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 or opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true. This may include your name, residential or postal address, telephone numbers, email address, date of birth, profession or occupation, employment details, financial situation, identification document numbers and copies, property ownership details, and details of properties you are buying, selling, leasing or enquiring about. We also collect and hold sensitive information (such as government-issued identifiers under AML/CTF requirements) only where required by law or with your express consent.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect identification and contact information (name, address, phone numbers, email, date of birth, occupation and employer), property and transaction information (property addresses, ownership and tenancy history, purchase or sale price, contract details, inspection records, and bidding or offer history), and from 1 July 2026, financial and verification information for AML/CTF compliance (driver's licence, passport, Medicare or other government ID; source of funds and source of wealth for transactions above prescribed thresholds; copies of identity documents). We also collect web and digital interaction data (IP address, browser type, device identifiers, pages visited, time on site, referral source, cookies, analytics data), your marketing preferences (SMS and email opt-in status, channel and frequency preferences, unsubscribe records), inspection and visit records (visitor logs, entry registers, and where notified, audio or video recordings of inspections), voice recordings (with your knowledge, recordings of inbound or outbound calls handled by our automated call systems for quality, training and follow-up purposes), and any other information you provide to us directly or that we lawfully receive about you from third parties. We also collect anonymous and aggregated information that does not personally identify you.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect personal information directly from you wherever reasonable and practicable. This includes when you access our website (fnco.au) or online forms; submit an enquiry, booking or contact form (including via third-party portals such as realestate.com.au, domain.com.au, apartments.com.au, homely.com.au); communicate with us by phone, SMS, email, post or in person; attend a property inspection or sign an entry register; sign agreements, contracts, applications, or AML/CTF identity verification documents; participate in surveys, competitions, promotions or research; or through cookies and other tracking technologies on our website. We may also collect personal information from third parties, including real-estate portals, credit reporting bodies and government entities (where lawful), your representatives (solicitors, conveyancers, accountants, advisers, brokers), your employer (for relocation or employer-sponsored transactions), AML/CTF verification service providers, and publicly available sources (title register, council records, electoral roll).

COOKIES
When you access our website, we may use cookies (small data files containing a unique identifier sent to your device) along with web beacons, pixels, browser local storage, and similar tracking technologies. These help us recognise your browser or device on return visits, remember your preferences, measure traffic and content performance, and support targeted advertising on third-party platforms such as Meta (Facebook/Instagram), Google and LinkedIn. You can configure your browser to refuse cookies, though some parts of our website may not function correctly without them. We may also log IP addresses and use website analytics tools (such as Google Analytics) to analyse trends and track user movements in aggregate.

WHAT HAPPENS IF WE CAN'T COLLECT YOUR PERSONAL INFORMATION?
If you do not provide us with the personal information we need, some or all of the following may happen: we may not be able to provide our products or services to you, either to the same standard or at all; for in-scope transactions under the AML/CTF Act 2006 we may be legally unable to proceed with the engagement; we may not be able to provide you with information about properties, projects or services that may interest you, including special opportunities or promotions; and we may be unable to tailor our website to your preferences.

FOR WHAT PURPOSES DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?
We collect, hold, use and disclose personal information to perform our business activities and provide quality real estate sales, leasing, advisory and project marketing services. Specifically, we use your personal information to respond to enquiries and provide information about properties, projects, products and services; to administer and improve our website and digital systems; to communicate with you, including direct marketing about properties and services we consider may interest you; to comply with our legal obligations under the AML/CTF Act 2006, the Property Occupations Act 2014 (Qld), the Residential Tenancies and Rooming Accommodation Act 2008 (Qld), and other applicable laws; to keep your contact details current; to process and respond to any complaint you make; and for the administrative, operational, planning, research and quality-assurance purposes of Fraser & Co and our related parties.

TO WHOM MAY WE DISCLOSE YOUR INFORMATION?
We may disclose your personal information to our personnel and authorised contractors who require it for their roles; our service providers (CRM and email — Zoho; cloud hosting — Google Workspace; automated call and SMS — Twilio; AML/CTF verification providers; IT administrators; mailing and printing services; payment processors; debt collectors; solicitors, accountants and consultants); property transaction counterparties (buyers, sellers, their legal and financial representatives, conveyancers, settlement agents); developers and project partners (for project marketing roles such as Laguna Waters, we share enquiry and pipeline information with the project owner or developer where you have enquired about that project); real-estate portals (REA, Domain, Apartments.com.au and similar) to publish listings and process enquiries; advertising platforms (Meta, Google, LinkedIn and similar) in the form of hashed audience data for targeted advertising; government and regulatory authorities (AUSTRAC, ATO, courts, tribunals, Office of Fair Trading) where required or authorised by law; and any other party with your express consent. We do not sell your personal information.

DIRECT MARKETING MATERIALS
We may send you direct marketing communications and information about properties and services we consider may interest you, in accordance with the Privacy Act 1988 (Cth) and the Spam Act 2003 (Cth). These may be sent by post, email, SMS, MMS, phone or via targeted digital advertising. Every electronic marketing message includes a clear opt-out mechanism. You can opt out at any time by using the unsubscribe link in any electronic marketing message, replying STOP to any marketing SMS, emailing info@fnco.au with the subject "Unsubscribe", or contacting our Privacy Officer. Once you opt out we will remove you from the relevant marketing list within a reasonable time. We may still send you transactional or service-related communications (such as contract documents, settlement updates, and AML/CTF verification requests) which are not direct marketing.

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 our Privacy Officer. Where we hold information you are entitled to access, we will try to provide it to you in a suitable form, usually within 30 days. We do not charge for receiving an access or correction request, but may charge a reasonable fee to cover the cost of providing access. In limited circumstances we may refuse access (for example, where granting access would unreasonably interfere with another person's privacy or breach confidentiality) — if we do, we will give written reasons and information on how to escalate. If you believe personal information we hold about you is incorrect, incomplete or out of date, you may request a correction and we will consider and, where appropriate, update our records. You may also request to interact with us anonymously or under a pseudonym, and you may withdraw consent to direct marketing at any time.

WHAT IS THE PROCESS FOR COMPLAINING ABOUT A BREACH OF PRIVACY?
If you believe your privacy has been breached, contact our Privacy Officer and provide details of the incident so we can investigate. We will acknowledge your complaint within a reasonable time and aim to resolve it promptly, in accordance with our complaints-handling procedures. We are also subject to the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals as soon as practicable, notify the Office of the Australian Information Commissioner (OAIC), and provide recommended steps to mitigate any risk to you. If you are not satisfied with our response, you may escalate to the OAIC (1300 363 992 or oaic.gov.au).

DO WE DISCLOSE YOUR PERSONAL INFORMATION TO ANYONE OUTSIDE AUSTRALIA?
We may disclose personal information to our service providers located outside Australia, including IT and cloud-hosting providers operating in the United States, the European Union, and other jurisdictions. Your personal information may be stored on servers or in cloud platforms based overseas, and while you continue to use our services you consent to this disclosure. We take reasonable steps to ensure that overseas recipients handle your information in accordance with the Australian Privacy Principles.
SECURITYWe take reasonable steps to protect personal information we hold from misuse, interference, loss, and unauthorised access, modification or disclosure. These steps include encryption in transit and at rest where practicable, access controls, staff training, and supplier due diligence. However, because the internet is inherently insecure, we cannot guarantee the security of information you transmit to us online, and any such transmission is at your own risk.

LINKS
Our website may contain links to other websites operated by third parties. We make no representations or warranties about the privacy practices of any third-party website and are not responsible for their content or privacy policies. Each third-party website is responsible for informing you of its own privacy practices.

CONTACTING US
If you have any questions about this Privacy Policy, or any concerns or feedback regarding the treatment of your privacy, please contact our Privacy Officer. We will respond within a reasonable time to discuss your concerns and outline options for resolution. Privacy Officer, Fraser & Co Pty Ltd — Email: info@fnco.au — Website: fnco.au — Address: Brisbane, Queensland, Australia.

CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our business, the law, or community expectations. The current version will always be published on our website with the date of last update shown at the top of the page. Where the changes are material, we will take reasonable steps to communicate them to you in advance.

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