‍6. ‘Personal data’ means any information relating to an identified or identifiable natural person. Depending on the nature of your interaction with us, the personal data we collect can include:

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• Name, address, telephone numbers, email address, identification numbers, driving license, and vehicle ownership, occupation, financial or payment information, insurance information, membership or subscription details, images, voice recordings, fingerprint, date of birth or age, and other information which you have provided us in any form or through interactions with us.
• Information from your use of our websites or other services including IP addresses and browsing or transactional history.
• Behavioural history such as dietary requirements and other preferences which you may express to us as you interact with our products and services.
• Employment and educational background, medical health and physical history, criminal history, ethnic and racial origin, nationality, religion, income levels, and other information related to your employment.
• Any other information of a personal nature which you disclose to us.

7. We collect personal data that you voluntarily provide to us. What personal data we collect depends on the purposes of the collection and what you have chosen to provide.

8. We use different methods to collect personal data, including the following:

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• You may give us your personal data by filling in physical or online forms, corresponding with us by post, phone, email, chatbot, or otherwise, visiting our websites, downloading or using our mobile applications, expressing an interest in, using, or purchasing services or products that we own or manage, signing up for our loyalty or other programs, creating an account with us, or subscribing to our mailing lists.
• We use CCTV systems and equivalent devices within the properties that we own or manage for safety and security reasons.
• Automated technologies or interactions: As you interact with our websites, platforms, applications, or equivalents, we may automatically collect technical data about your equipment, browsing actions, and patterns.

9. Depending on your relationship with us, we may also collect your personal data from third-party sources, for example, from our business partners, entities or other parties investing within the Atrio Property Group, your employers, referees, educational institutions, previous employers, family members, friends, entities or other parties that you have authorised to disclose information to us, and/or from public agencies or other public sources.

10. The collection, use, and disclosure of your personal data are generally for the efficient operation of our businesses. More details of the purposes for which we collect, use, and disclose personal data are set out below.

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11. The purposes include but are not limited to:

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• Processing your transactions with us and/or our clients and providing products and services to you.
• Verifying your identity, managing our relationship with you, and communicating with you.
• Optimizing our operations and the products and services we and/or our clients offer to you.
• Conducting surveys, research, data matching, and statistical analysis.
• Facilitating business asset transactions.
• Conducting due diligence and managing commercial risks.
• Facilitating administrative purposes.
• Detecting, preventing, or otherwise addressing security, safety, or technical issues.
• Complying with laws and regulations.
• Preventing crime, assisting in law enforcement and investigations by relevant authorities.
• Managing our business, or our client’s business.

12. If you sign up to our customer loyalty program, create an account on our applications or platform, or sign up to our mailing lists, we will collect, use, and disclose your personal data for marketing our products and services and those of our partners and business associates, and for promotional and publicity purposes.

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13. If you make a job application with Atrio Property, we may collect, use, and disclose your personal data to facilitate and process your employment application and to facilitate and manage your employment with us.

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14. In addition to collecting, using, disclosing, and processing your personal data with your consent or for performance of a contract entered with you, we may also do so to support our legitimate business interests or because it is necessary to comply with a legal obligation.

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15. We may also collect, use, disclose, and process your personal data without your consent where this is required or permitted by law.

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16. When we contact or send you information for the purposes described, we may do so by post, e-mail, SMS, telephone, or such other means provided by you.

17. We may disclose or share your personal data with clients with whom we are contracted to sell on behalf of, or manage projects on behalf of for the purposes described.

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18. We may disclose your personal data for the purposes described or as required or permitted by law, for example, to third-party vendors and service providers, owners of the properties, third parties with whom we conduct joint marketing, cross promotions, and regulatory authorities.

19. We will implement adequate security measures to mitigate unauthorized or unintended access. However, we cannot be held responsible for unauthorized or unintended access that is beyond our control.

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20. We keep your personal data only for so long as we need it to fulfill the purposes we collected it for and to satisfy our business and/or legal purposes where permitted under applicable laws. Typically, our data retention periods range from 3 to 15 years.

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21. Where the data retention period has expired, we erase or otherwise destroy the relevant personal data.

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22. In some circumstances, we may anonymize your personal data so that it can no longer be associated with you.

23. Depending on the jurisdiction you are in or where we operate, you may enjoy certain rights at law in relation to our collection, use, disclosure, and processing of your personal data.

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24. We may be permitted under applicable laws to refuse a request.

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25. If you have a complaint, you may contact us. You also have a right to lodge a complaint with any data protection regulator or authority having jurisdiction over us.

26. If you have any feedback or issues in relation to your personal data or about this Policy, you may write to us on the details below:

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Atrio Property Pty Ltd,

1/630 Coronation Drive,

Toowong, QLD 4066

info@atrioproperty.com.au.

27. If you have a complaint about our compliance with the Australian Privacy Principles or in relation to how we handle a request to access or correct your personal information, you may contact us using the details provided in Part I “Contacting Us” above. We will make reasonable efforts to respond to your complaint within a reasonable time. If we are unable to satisfactorily resolve your privacy concerns, you can contact the Office of the Australian Information Commissioner on their website www.oaic.gov.au.

16th May 2024