Privacy Policy - Religare Realty

Religare Realty Version 2026-09-19 · Effective 19 September 2026

1. About this policy

Religare Realty is a registered business name of Rakesh Suresh Parmar, ABN 89 920 286 676, a sole trader operating a buyer’s agency in New South Wales. In this policy, “we”, “us” and “our” mean Religare Realty.

This policy explains how we collect, hold, use, disclose and protect personal information. It applies to everything we do, including:

our website at religare.com.au/religare-realty
our enquiry and booking pages at buy.religare.com.au
our advertising on Google, Meta (Facebook and Instagram) and similar platforms
the buyer’s agency services we provide to clients

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

2. Why the Privacy Act applies to us

Most Australian businesses with an annual turnover of $3 million or less are exempt from the Privacy Act 1988 (Cth). That exemption does not apply to us.

Since 1 July 2026, real estate professionals — including buyer’s agents — are reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). A small business that is a reporting entity must comply with the Privacy Act in relation to its AML/CTF activities.

We have chosen to apply the Australian Privacy Principles (APPs) to everything we do, not only to our AML/CTF work. You should not have to work out which set of rules covers which piece of your information.

3. What personal information we collect

3.1 When you enquire

your name, email address, phone number and the general area you live in
what you are looking for: the type of service you want, your budget range, the markets or regions you are interested in, your target rental yield
the type of entity you intend to buy in (for example, personally, jointly, through a company, family trust or self-managed super fund)
where you are up to with finance (for example, not started, speaking to a broker, pre-approved, cash buyer)
whether someone referred you to us, and who
whether you consented to us contacting you about your enquiry, and separately whether you consented to receiving market updates — including the date, the form you used, and the version of this policy in force at the time

3.2 When you become a client

your residential address and postal address
the signed buyer’s agency agreement, and the dates it was sent, signed and served back to you
your written brief, bidding limits and instructions
the property you buy: address, contract date, finance and building-and-pest due dates, the date the contract went unconditional, the settlement date, and the purchase price
our correspondence with you — emails, text messages, notes of calls and meetings

3.3 Identity and source-of-funds information (AML/CTF)

Before we begin work, the law requires us to verify who you are. We collect:

full name, date of birth and residential address for each individual client, authorised signatory, trustee, director and beneficial owner
the type, number and issuing body of the identity document we used to verify you, and the result and date of that verification
for companies, trusts and self-managed super funds: the structure of the entity and the identity of anyone who owns or controls 25% or more of it, or who otherwise controls it
information about the source of the funds being used for the purchase
the outcome of a politically exposed person (PEP) and sanctions screen, who performed it, and the date it is next due for review
a risk rating, and whether enhanced due diligence is required

We keep a copy of the identity documents you give us. We hold each copy for seven years after the end of our business relationship with you, in encrypted, access-controlled storage that is separate from our CRM. We do not upload identity documents to your contact record in our CRM, and we do not hold them anywhere else.

This is a deliberate, risk-assessed choice under our AML/CTF Program, and these are the reasons for it:

The document itself is the primary evidence that we verified you properly. A typed record of its details is not the same evidence if AUSTRAC asks us to demonstrate how we met our obligations.
Property purchases are high-value and infrequent, so the period over which a verification may later be questioned is long.
Our client numbers are small enough that copies can be held under tighter controls than a larger firm could realistically maintain.

Against that we weigh the risk of holding them at all, so the controls are specific and not negotiable: encrypted storage, access restricted to Rakesh Parmar alone, never uploaded to our CRM, never shared with a third party, and destroyed once the seven years expire. We review this decision every year, and if the balance changes we will change the practice and update this policy.

The Office of the Australian Information Commissioner encourages reporting entities to record the verification details and destroy the copy. We have taken a different approach for the reasons above — which that guidance permits where the decision is risk-assessed and documented — and we would rather state that plainly than let you assume otherwise. If you would prefer us not to hold a copy of a particular document, tell us and we will discuss it with you.

Please do not email us photographs or scans of identity documents unless we have asked you to, and never send them to an address you have not confirmed with us by phone.

3.4 Information we collect automatically

When you visit our website or enquiry pages, we or our advertising partners may collect:

your IP address, approximate location, browser and device type
the pages you viewed, how long you stayed, and what you clicked
the advertisement, ad set and campaign you arrived from, and the click identifier that Google or Meta assigned to your click
if you submitted a lead form directly inside Facebook or Instagram, the identifier Meta assigns to that submission

Section 11 explains the cookies and tracking tags involved and how to turn them off.

3.5 Sensitive information

We do not seek sensitive information (such as health, racial or ethnic origin, religious beliefs, or criminal record) and you should not send it to us.

Two narrow exceptions arise from the law we operate under:

a PEP or sanctions screen may return a result that touches on political affiliation or law-enforcement matters. We collect and hold only the outcome of that screen, and only because the AML/CTF Act requires it.
if you tell us about a personal circumstance that affects your purchase — a relationship breakdown, an illness, a bereavement — we will record only what we need in order to act for you properly.

3.6 Information about other people

If you give us personal information about someone else — a co-purchaser, a trustee, a beneficial owner, a family member — please make sure they know you are giving it to us and point them to this policy.

4. How we collect personal information

Wherever possible we collect personal information directly from you: through our enquiry forms, in phone calls and meetings, by email and text message, and in the documents you sign.

We also collect information:

from Google and Meta, when you click an advertisement or submit a lead form on their platforms
from third-party verification and screening providers, when we check your identity or run a PEP and sanctions screen
from publicly available sources — ASIC registers, ABN Lookup, land title and property data services — when we verify an entity or research a property
from people who refer you to us, where they have told you they are doing so

5. Why we collect it, and what we use it for

Purpose	What this covers
Responding to your enquiry	Contacting you, understanding your brief, arranging a discovery call
Providing our services	Searching, inspecting, shortlisting, appraising, negotiating, bidding, and managing a purchase through to settlement
Meeting our AML/CTF obligations	Customer due diligence, ongoing due diligence, PEP and sanctions screening, and reporting to AUSTRAC where the law requires it
Meeting our NSW property agency obligations	Preparing and serving the agency agreement, and keeping the records required under the Property and Stock Agents Act 2002 (NSW)
Administering our business	Invoicing, record keeping, insurance, obtaining professional advice, and resolving disputes
Marketing — only with your consent	Sending market updates and offers. See section 9
Measuring our advertising	Understanding which advertisements produce genuine enquiries. See sections 10 and 11

We will not use your personal information for an unrelated purpose unless you would reasonably expect it, you have consented, or the law requires or authorises it.

6. Dealing with us anonymously

You can browse our website without telling us who you are, and you can ask general questions about how we work by phone without giving your name.

We cannot provide buyer’s agency services anonymously. The law requires us to verify the identity of every client before we begin, and a written agency agreement has to name the parties.

7. Who we disclose personal information to

We disclose personal information to:

AUSTRAC and other regulators, where required by law
service providers engaged for your purchase — building and pest inspectors, conveyancers and solicitors, strata report providers, valuers, quantity surveyors — to the extent needed to deliver that service
selling agents and vendors, to the extent needed to make an offer, negotiate or bid on your behalf
our professional advisers — accountants, lawyers, insurers — under confidentiality obligations
our technology providers, who host and run the systems described in section 8
law enforcement agencies and courts, where required or authorised by law

We do not sell personal information, and we do not disclose it to anyone for their own marketing purposes.

Referrals to a mortgage broker. Religare Home Loans is a separate business, operated by a separate legal entity (Religare Group Pty Ltd, ABN 82 642 516 434). We will not pass your details to it, or to any other broker, without asking you first and getting your agreement at the time.

One thing we cannot tell you. If we are required to report a matter to AUSTRAC, the AML/CTF Act prohibits us by law from telling you — or anyone else — that we have done so, or that an investigation may be underway. This is the “tipping-off” prohibition in section 123 of that Act. It is the one circumstance in which we may not be able to answer a question about your information fully.

8. Where your information goes — disclosure overseas

Yes, we disclose personal information to recipients outside Australia. We think you should know exactly where, so here is the full list.

Provider	What it does	Where the information is held
HighLevel Inc. (GoHighLevel)	Our CRM. Holds enquiry records, contact details, your brief, correspondence, text messages and appointment history	United States (Amazon Web Services and Google Cloud Platform)
Mailgun / Sinch	Sends our email	United States
Twilio	Sends and receives our text messages and routes our calls	United States
Meta Platforms, Inc.	Lead ads, the tracking pixel on our pages, and advertising measurement	United States, and other countries in which Meta operates
Google LLC	Google Ads, advertising measurement, and Google Workspace (our email and document storage)	United States, and other countries in which Google operates

Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, including through the contracts and data processing terms each provider offers. You should be aware that an overseas recipient may be required to disclose information under the law of its own country, and that Australian privacy law may not be enforceable against it in the same way.

If you would prefer we deal with you by phone and post rather than through these systems, tell us and we will do our best to accommodate it — though it will slow things down, and the AML/CTF records we are required to keep will still be held electronically.

9. Marketing, and how to stop it

We send market updates and offers only to people who have ticked the marketing consent box. That box is never pre-ticked, and you can submit any of our forms without ticking it. Declining marketing has no effect on the service you receive.

Every marketing email and text message we send carries an unsubscribe option. You can also opt out at any time by emailing rakesh@religare.com.au or replying STOP to any text message. We action opt-outs promptly and in any case within 5 business days, as the Spam Act 2003 (Cth) requires.

Messages about a live enquiry or a transaction we are working on — appointment confirmations, contract deadlines, settlement updates — are not marketing, and continue regardless of your marketing preference.

Case studies and social media. If you become a client, our agency agreement asks for your consent to use de-identified information about your purchase — general property type, region, approximate price range — in marketing. We never publish your name, the property address, or anything else that identifies you or the property without asking you separately, in writing, at the time. You can withdraw that consent whenever you like.

10. Automated processing and decision-making

We use a lead score — a number our CRM calculates from the information in your enquiry — to decide which enquiries to call back first.

That is all it does. It is a prioritisation tool. No decision that affects your rights or interests is made solely by a computer program. A person decides whether we can help you, whether to take you on as a client, and what we recommend. A low lead score does not mean we will not call you.

Our AML/CTF risk rating and PEP screening involve automated checks against sanctions and PEP databases, but every result is reviewed by a person before anything follows from it, and the person who reviewed it is recorded.

11. Cookies, pixels and advertising tags

Our website and enquiry pages use:

essential cookies, which make forms and bookings work
the Meta pixel and Conversions API, which tell us that an advertisement produced an enquiry
Google Ads tags and conversion tracking, which do the same for Google
GoHighLevel’s own tracking, which links a form submission back to the advertisement that produced it

These tools set cookies and may match your activity to an existing Google or Meta account. You can control them:

In your browser — block or delete cookies through your browser settings
Meta — Settings → Accounts Centre → Your information and permissions → Off-Meta activity
Google — myadcenter.google.com and adssettings.google.com
Industry opt-out — youronlinechoices.com.au

Blocking these tools does not stop you using our website or submitting an enquiry.

12. How we store and secure your information

Personal information is held electronically in the systems listed in section 8, and in Google Workspace. Identity documents and source-of-funds material are held separately from our CRM, in encrypted storage restricted to Rakesh Parmar. We hold very little on paper; what exists is kept in a locked location.

We protect it with multi-factor authentication on every account, access limited to people who need it, encrypted transmission, device encryption, and regular review of who has access to what. Where a provider offers a stronger security setting, we turn it on.

No system is perfectly secure. If you believe your information has been compromised, contact us immediately using the details in section 16.

13. How long we keep it, and when we destroy it

Information	How long we keep it
AML/CTF records — identity verification records, due diligence records, source of funds, screening outcomes, transaction records	7 years after the end of our business relationship with you, as the AML/CTF Act requires
Copies of identity documents	7 years after the end of our business relationship, then destroyed. Held in encrypted, access-controlled storage separate from our CRM — see section 3.3
Agency agreements and transaction records	For the period required under the Property and Stock Agents Act 2002 (NSW) and its regulations, or the AML/CTF period above, whichever is longer
Enquiries that do not become clients	24 months from our last contact with you, after which we destroy or de-identify the record
Marketing consent and opt-out records	For as long as we market, plus the period required to demonstrate compliance with the Spam Act 2003 (Cth)
Website and advertising analytics	As set by the platform — typically no more than 26 months

When we no longer need personal information and no law requires us to keep it, we destroy it or de-identify it.

14. Accessing and correcting your information

You can ask us for a copy of the personal information we hold about you, and you can ask us to correct anything that is wrong, out of date, incomplete or misleading.

How to ask: email rakesh@religare.com.au or call 0468 092 579. Ask in writing if you can — it helps us get it right.

What happens then: we will acknowledge your request within 5 business days and respond within 30 days. There is no charge for making a request. If a request takes substantial work to fulfil we may charge a reasonable cost-based fee, and we will tell you what it is before we start.

If we say no, we will tell you why in writing and explain how to complain. The most common reasons we would refuse are that the law requires us to (including the tipping-off prohibition in section 7), or that giving you access would unreasonably affect another person’s privacy.

If we correct information we have already given to someone else, we will tell that person about the correction if you ask us to, unless it is impracticable or unlawful.

15. Data breaches

We have a response plan for suspected data breaches. If a breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as the Notifiable Data Breaches scheme requires.

16. Complaints

Step 1 — tell us.

Rakesh Parmar, Privacy Officer
Religare Realty
8 Dewdrop Place, Acacia Gardens NSW 2763
rakesh@religare.com.au · 0468 092 579

We will acknowledge your complaint within 5 business days and give you a substantive written response within 30 days.

Step 2 — if you are not satisfied, you can take it to:

Office of the Australian Information Commissioner — oaic.gov.au · 1300 363 992 · GPO Box 5288, Sydney NSW 2001
NSW Fair Trading — fairtrading.nsw.gov.au · 13 32 20, for complaints about our conduct as a property agent
The Property Services Commissioner, under the Property and Stock Agents Act 2002 (NSW)

You do not have to come to us first, but it is usually the fastest way to get the problem fixed.

17. Changes to this policy

We review this policy at least once a year and whenever our practices or the law change. The current version is always at religare.com.au/religare-realty/privacy-policy. The version number and date at the top tell you which version is in force.

When you submit an enquiry form, we record which version of this policy was in force at that moment, so that your consent stays meaningful even after the policy changes. If we make a change that materially affects how we handle information we already hold, we will tell affected clients directly.

Version 2026-09-19 · Effective 19 September 2026 · Next scheduled review September 2027

Religare Realty is a registered business name of Rakesh Suresh Parmar, ABN 89 920 286 676.