Privacy Policy

ABOUT THIS PRIVACY POLICY

123 Noosa Pty Ltd as Trustee for the 123 Noosa Unit Trust ABN 25 419 460 419, trading as Reed & Co Estate Agents, and its affiliates including Reed & Co Sales Pty Ltd ACN 626 785 162 (“we”, “us”, “our”) respect your privacy. This Privacy Policy explains how we collect, hold, use, disclose and protect your Personal Information, including how we use artificial intelligence and automated systems, and how you can access, correct or complain about your information. By using our website or services, or providing us your Personal Information, you accept this Privacy Policy. If you do not agree, please do not provide us with your Personal Information, though we may then be unable to provide our services to you.

Your use of our website is also governed by our Website Terms of Use, which apply together with this Privacy Policy.

“Personal Information” means information that can identify you, as defined in the Privacy Act 1988 (Cth) — for example your name, address, date of birth, contact details, occupation, basic financial and payment details, references, photo identification, and credit and assessment details. It includes “Sensitive Information” as defined in that Act. We support the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), as amended from time to time (including by the Privacy and Other Legislation Amendment Act 2024 (Cth)). We may update this Policy at any time by posting the current version on our website; continued use of our services means you accept the updated Policy.

DEALING WITH US ANONYMOUSLY

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym. However, in most cases we will need your Personal Information to provide our services or respond to your enquiry, and if you choose not to provide it we may not be able to assist you.

WHAT WE COLLECT AND HOW

We collect Personal Information (including Sensitive Information) and non-Personal Information about our clients, potential clients and their personnel; other individuals we deal with in acting for clients; our suppliers and their employees; our employees, contractors and prospective personnel; and others who interact with Reed & Co. Estate Agents.

We usually collect this information directly from you or your representatives (e.g. solicitor, accountant or financial advisor), and sometimes indirectly, including through:

your enquiries and communications with us (by phone, email, mail, in person, online, via our website or social media, or by giving us your business card);
forms, applications and authorities you complete, and your use of our website, apps, blogs and social media; • open for inspections, auctions, events, competitions, surveys and after-sale follow-ups; • enquiring about, or negotiating the purchase or sale of, a property;
Strata or Bodies Corporate and their managers, publicly available sources, and our own records; and • third parties such as credit reporting agencies, financial institutions and providers that analyse our website traffic.

If you give us Personal Information about another person, you confirm you are authorised to do so and that they have consented and been made aware of this Policy.

The kinds of Personal Information we collect include:

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Identity Data — such as your name, age or date of birth, occupation, and proof of identity (including photo identification), including information we collect as part of our anti-money laundering and counter-terrorism financing (AML/CTF) verification process.

Website data, cookies and analytics

When you visit our website, our server collects anonymous “click-stream” data (such as browser and device type, IP address, and the pages, dates and times of your visit) to help us evaluate and improve performance. We use cookies to recognise your device and coordinate your access to our pages; you can block or erase cookies through your browser settings. We also use third-party analytics, advertising and marketing technologies — including iRealty, Sonar, Meta and Google Analytics — which may use cookies and similar technologies to collect information such as your IP address, location and device data, and pages and links viewed. This information may be shared with those providers, who handle it under their own privacy policies, and you can opt out of certain advertising through the settings they offer. Links on our website may take you to third-party sites, for which we are not responsible.

HOW WE USE AND DISCLOSE YOUR INFORMATION

We collect, hold, use and disclose Personal Information to:

conduct our business — appraising, advertising, and acting as agent for the buying and selling of properties; • provide, market and improve our products, services, website and applications, and communicate with you about properties and services you may be interested in;
respond to enquiries, feedback and complaints, and approve transactional matters; • conduct credit, identity and reference checks, and assist with utilities, finance and related services on your behalf;
operate our CRM, marketing and business systems — including automation and AI features that organise, prioritise, draft, match and analyse information (see “Artificial Intelligence and Automated Decision-Making” below);
arrange repairs or maintenance, maintain our systems and social media, and meet our legal, insurance and governance obligations.

We do not sell your Personal Information, and we do not permit our service providers to use it to train their own or publicly available AI models, except as described in this Policy or as permitted by law. We may disclose your Personal Information (with your consent, where required by law, or otherwise as reasonably expected) to:

our officers, employees, affiliates, related bodies corporate, co-agents, representatives, contractors and trusts, and your representatives;
prospective purchasers concerning your property, and the general public and media when advertising or marketing your property;
service providers that assist our business (including hosting, data storage, software and AI providers, database managers, marketing entities, tradespeople and debt collectors, whether in or outside Australia); • professional providers (lawyers, conveyancers or accountants) for services associated with the sale or purchase of property;
courts, tribunals, statutory bodies and law-enforcement or government agencies as required or authorised by law (including to prevent money laundering);
a member of our team (such as a sales agent) who ceases their engagement with us and is entitled to export their client database, which may contain your Personal Information, to themselves or their new agency; and • any person or entity to whom we sell, merge or transfer our business or assets (or propose to), as part of that transaction.

ARTIFICIAL INTELLIGENCE AND AUTOMATED DECISION-MAKING

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As artificial intelligence (AI) becomes embedded in modern business, we use commercially available AI assistants and productivity tools (for writing, summarising, note-taking and research) and AI and automation features within our CRM, marketing and business systems, using reputable, business-grade providers with appropriate security and confidentiality protections. We may use these tools to draft and summarise communications and documents; take notes and transcribe; research and prepare market and comparable-sales information; generate and prioritise contact and marketing lists; match and rank prospective buyers against properties; assess and prioritise enquiries, leads and buyer or seller suitability; and assist with identity, reference and background checks. The Personal Information involved may include your contact details, property preferences and budget, enquiry and interaction history, financial information relevant to a transaction, references, identification and other application details. We limit what we input to what is reasonably necessary and avoid inputting Sensitive Information unless it is necessary and appropriately protected.

Automated decisions, human oversight and your rights

Some tools use automation or AI to substantially and directly assist in making decisions that may affect you — for example, matching, ranking or prioritising prospective buyers or sellers against available properties, prioritising enquiries and leads, and assisting in assessments. In line with the transparency requirements introduced by the Privacy and Other Legislation Amendment Act 2024 (Cth) (which apply from 10 December 2026), the kinds of Personal Information used in these processes include your contact details, property preferences and budget, enquiry and interaction history, financial information, references, identification and other application details. We do not intend for decisions that significantly affect your rights or interests to be made solely by automated means — a member of our team reviews and is responsible for material decisions (such as whether to accept an offer) before they take effect. We remain responsible for the information we place into these tools and for decisions we make with them, take reasonable steps to check the accuracy of AI outputs before relying on them, and do not permit your Personal Information to be used to train publicly available AI models except where the law permits or you have consented. You may contact our Privacy Officer to ask whether AI or automation was used in a decision affecting you, to request human review, to raise concerns, or to seek correction.

Combining and enriching information

We use an internal tool, developed for the exclusive use of our agency, to combine Personal Information we hold about you with information from other sources (including publicly available information and information from third parties associated with our business) to develop insights, better understand your preferences, and personalise and improve our services. This is carried out internally within our agency, and we do not disclose your Personal Information to external parties for this purpose except as otherwise described in this Policy.

EMPLOYEE RECORDS

Under the Privacy Act 1988 (Cth), acts and practices directly related to the employment relationship between us and our current and former employees, and their employee records, are generally exempt from the APPs. To the extent that exemption applies, this Policy does not apply to our handling of those employee records.

SERIOUS INVASIONS OF PRIVACY

Australian law now includes a statutory cause of action (effective 2025 under the Privacy and Other Legislation Amendment Act 2024 (Cth)) for serious invasions of privacy that are intentional or reckless, where a person had a reasonable expectation of privacy. We handle your Personal Information, images and information gathered during inspections, appraisals and transactions with appropriate care and respect for your reasonable expectations of privacy.

SECURITY, RETENTION AND DATA BREACHES

We take reasonable steps to protect Personal Information from misuse, interference, loss and unauthorised access, modification or disclosure — including electronic and physical security, access controls, staff training,

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password protection, and requiring our service providers (including cloud, software and AI providers) to apply appropriate protections. We take reasonable steps to destroy or de-identify Personal Information when it is no longer needed and we are not required by law to retain it. You can help protect your information by closing your browser after each session, avoiding public computers, and never sharing your username or password; contact us immediately if you believe your credentials have been compromised. No transfer of data over the internet is completely secure, so we cannot guarantee the security of information transmitted online. If a data breach occurs that is likely to result in serious harm, we will investigate and notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, in accordance with the Notifiable Data Breaches scheme, including breaches involving our service providers.

OVERSEAS DISCLOSURE

Some of our service providers — including hosting, data storage, software, AI and international property advertising providers — are located overseas, including in New Zealand, the Philippines, the United States and other countries from time to time. When we disclose Personal Information (which may include Sensitive Information) to these recipients, they may not be subject to privacy laws similar to the APPs and may be subject to foreign laws that could compel disclosure. By providing us with your Personal Information, you consent to this overseas disclosure. If an overseas recipient handles your information in breach of the APPs, you may not be able to seek redress under the Privacy Act or in the overseas jurisdiction, and we may not be accountable under the Privacy Act. You can withdraw your consent at any time by contacting our Privacy Officer, though we may then be unable to provide some services.

DIRECT MARKETING

We may include your Personal Information in our databases and use it (including with automated tools and AI to organise, segment and personalise) for ongoing marketing about properties and services that may interest you. If you provide your email address, you consent to receiving our email communications and campaigns. To stop receiving marketing or to update your preferences, contact our Privacy Officer, email sales@reedandco.co, or use the unsubscribe option in our communications.

ACCESS, CORRECTION AND SOCIAL MEDIA

Subject to the exceptions in the Privacy Act 1988 (Cth), you may seek access to and correction of the Personal Information we hold about you by contacting our Privacy Officer, Bianca Pascoe, at bianca@reedandco.co. We will verify your identity and advise of any likely cost in advance. Where we maintain a presence on social media, any information you provide there may be publicly visible and will be handled as described in this Policy, and we may remove material we consider inappropriate or offensive.

CHANGES, COMPLAINTS AND CONTACT

We review this Policy from time to time to reflect new laws and technology (including developments in privacy law and AI) and changes to our operations. The current version is at www.reedandco.co/privacy-policy or available from our Privacy Officer at bianca@reedandco.co.

If you have questions or wish to complain about how we handle your Personal Information, contact our Privacy Officer at bianca@reedandco.co. We may ask you to put your complaint in writing, and will usually respond within 30 days. If we cannot resolve your concerns, you can contact the Office of the Australian Information Commissioner:

GPO Box 5218, Sydney NSW 2001 · Email: enquiries@oaic.gov.au · Tel: 1300 363 992 · www.oaic.gov.au