Privacy Policy

      PRIVACY POLICY 

1 ABOUT US
Ray White Core Group (“we”, “us”, or “our”) is a real estate agency operating under the Ray White franchise brand across multiple offices in Victoria, Australia. We provide residential and commercial real estate services including sales, property management, leasing, and business development.
We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act.

2 PERSONAL INFORMATION WE COLLECT
The types of personal information we collect depend on your relationship with us. We may collect:

2.1 From Vendors and Buyers (Residential and Commercial Sales)
• Full name, address, date of birth, and contact details
• Financial information including income, employment status, and loan details
• Property ownership details and title information
• Tax File Number (in limited circumstances, where required by law)
• Identification documents (driver’s licence, passport, or other government-issued ID) for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• Signature and execution details on contracts and agency agreements

2.2 From Landlords and Tenants (Property Management)
• Full name, date of birth, and contact details
• Rental history, references, and employment details
• Financial information for tenancy applications and rental assessments
• Identification documents for the purposes of the AML/CTF Act
• Details of the property, lease terms, and inspection records
• Maintenance requests and dispute records

2.3 From Job Applicants and Staff
• Full name, date of birth, address, and contact details
• Employment history, qualifications, and references
• Police check results and licence verification details
• Bank account and superannuation fund details (for payroll purposes)
• Tax file numbers and ABN/ACN details (for contractors)
• Emergency contact information

2.4 From Website and Digital Users
• Name, email address, and phone number submitted via contact or enquiry forms
• IP address, browser type, and device information collected via cookies and analytics tools
• Property search preferences and enquiry history

We collect only the personal information that is reasonably necessary for our functions and activities. Where practicable, we will allow you to interact with us anonymously or under a pseudonym.

3 HOW WE COLLECT PERSONAL INFORMATION
We collect personal information in the following ways:
• Directly from you — when you complete an agency agreement, tenancy application, employment form, or contact us by phone, email, or in person
• From third parties — including referees, previous landlords, financial institutions, conveyancers, and government bodies such as Land Use Victoria
• Through our website — including enquiry forms, property search tools, and subscription sign-ups
• Through our real estate platforms — including REA Group (realestate.com.au), Domain, VaultRE, Nurture Cloud, and PropertyMe
• Through CCTV and property access logs at our offices or managed properties, where this is clearly disclosed
Where we collect personal information about you from a third party, we will take reasonable steps to ensure you are aware of the collection and its purposes.

4 WHY WE COLLECT, HOLD, USE, AND DISCLOSE PERSONAL INFORMATION
We collect, hold, use, and disclose personal information for the following purposes:

4.1 Primary Purposes
• To provide real estate services including residential and commercial sales, property management, and leasing
• To prepare and execute agency agreements, contracts of sale, lease agreements, and other legal documents
• To assess tenancy applications and manage tenancies in accordance with the Residential Tenancies Act 1997 (Vic)
• To manage our trust accounts and financial reporting obligations under the Estate Agents Act 1980 (Vic)
• To verify client identity in accordance with our Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations
• To process commission and fee payments
• To manage employment, contracting, and payroll

4.2 Secondary Purposes
• To market our services to you, including property listings, newsletters, and market updates (subject to your consent)
• To improve our services, systems, and client experience
• To train and develop our staff
• To comply with legal, regulatory, and reporting obligations
• To investigate complaints or disputes
• To protect the safety and security of our offices and managed properties

We will not use or disclose your personal information for a purpose that is not related to the primary purpose for which it was collected, unless you have consented, or unless an exception under the Privacy Act applies.

5 DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to the following parties:

5.1 Within Australia
• The Ray White Group and other Ray White franchisees, for the purpose of providing referral services or shared services
• Conveyancers, solicitors, mortgage brokers, and financial institutions involved in a sale or tenancy transaction
• Government agencies including Consumer Affairs Victoria, Land Use Victoria, the ATO, and AUSTRAC (as required)
• Courts and tribunals including VCAT
• Our third-party service providers including property management software (PropertyMe, VaultRE), CRM providers (Nurture Cloud), marketing platforms, and IT support providers
• Tradespersons and property maintenance contractors managing repairs at properties
• Our external accountants, auditors, and legal advisers
• Other real estate agents involved in a co-agency or referral arrangement, with your knowledge

5.2 Overseas Disclosure
We do not routinely disclose personal information to overseas recipients. Where we use cloud-based services or platforms that store data offshore (such as certain CRM or marketing tools), we take reasonable steps to ensure those providers comply with standards substantially similar to the APPs. Where such disclosure is made, we will ensure it is compliant with APP 8.

6 DIRECT MARKETING
We may use your personal information to send you marketing communications about our services, including property listings, market updates, newsletters, and event invitations. We will only do this where:
• You have provided your consent; or
• We reasonably believe you would expect to receive such communications based on your prior dealings with us.
You may opt out of receiving marketing communications at any time by:
• Clicking the ‘unsubscribe’ link in any email we send; or
• Contacting us directly using the details in clause 12 of this policy.
We will action your opt-out request promptly and within a reasonable timeframe. We will not charge you for opting out.

7 ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING (AML/CTF)
From 1 July 2026, Ray White Core Group is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). We are required by law to collect, verify, and retain certain personal information from our clients.

As a reporting entity, we are required to:
• Collect and verify the identity of vendors, buyers, landlords, and other clients before providing designated services
• Collect information about beneficial ownership where applicable
• Report suspicious matters to AUSTRAC
• Retain identity verification records for a minimum of 7 years
The information collected for AML/CTF purposes may be disclosed to AUSTRAC and other relevant law enforcement agencies as required by law. We cannot provide services to you if you are unable or unwilling to provide the required identification.

8 SECURITY OF PERSONAL INFORMATION
We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, and disclosure. These steps include:
• Password-protected and encrypted software systems for storing client and property data
• Restricted access to personal information on a need-to-know basis
• Secure storage of physical documents containing personal information
• Regular staff training on privacy and data security obligations
• Secure disposal of personal information that is no longer required
While we take all reasonable precautions, no data transmission or storage system can be guaranteed as completely secure. If you believe your personal information held by us may have been compromised, please contact us immediately.

Data Breach Response
If we become aware of a data breach that is likely to result in serious harm to an individual, we will notify the affected individual(s) and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

9 RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We retain personal information for as long as it is needed to fulfil the purpose for which it was collected, or as required by law. Key retention periods include:

Category of Information Retention Period
Client identity verification records (AML/CTF) Minimum 7 years from the end of the customer relationship
Contracts of sale and agency agreements Minimum 7 years from completion of the transaction
Tenancy files and records Minimum 7 years from the end of the tenancy
Trust account records Minimum 7 years (as required by the Estate Agents Act 1980 (Vic))
Employment and contractor records Minimum 7 years from termination of employment or engagement
Marketing and newsletter contacts Until opt-out is requested, or 3 years of inactivity

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.

10 ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
10.1 Your Right to Access
You have the right to request access to personal information that we hold about you. To make an access request, please contact us using the details in clause 12. We will respond to your request within 30 days.
In some circumstances, we may be required or permitted by law to refuse access to certain personal information. If we refuse access, we will advise you in writing of the reasons for the refusal and the mechanisms available to complain about the refusal.

10.2 Your Right to Correction
If you believe that personal information, we hold about you is inaccurate, incomplete, or out of date, you may request that we correct it. We will take reasonable steps to correct the information within 30 days of receiving your request.

11 COOKIES, WEBSITE ANALYTICS, AND DIGITAL COMMUNICATIONS
Our website may use cookies and similar tracking technologies to improve your browsing experience and collect analytics data. Cookies are small data files stored on your device that help us understand how our website is used.
You may configure your browser to refuse cookies; however, this may limit your ability to use certain features of our website. We use third-party analytics tools including Google Analytics to understand website traffic. These tools may collect data such as your IP address, browser type, and pages visited, subject to their own privacy policies.
When you send us an email or complete an online form, the information you provide will be collected and used in accordance with this Privacy Policy.

12 COMPLAINTS AND CONTACT US
If you have a concern about how we have handled your personal information, or if you believe we have breached the APPs, we invite you to contact us in the first instance. We take privacy complaints seriously and will investigate and respond to all complaints within a reasonable timeframe.

13 CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or regulatory requirements. The updated policy will be published on our website and will take effect from the date of publication. We encourage you to review this policy periodically. Where changes are material, we will notify clients and staff directly.

14 GOVERNING LAW
This Privacy Policy is governed by the laws of the State of Victoria, Australia, and the Commonwealth of Australia, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.